Pearson v. Colt Oilfield Services, LLC et al

Western District of Texas, txwd-5:2018-cv-01029

Unopposed MOTION for Extension of Time to File Response/Reply as to {{22}} Response in Opposition to Motion, by Paul Duffala, Douglas Pearson.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DOUGLAS PEARSON and JAMES ADKINS, individually and on behalf of all others similarly situated under 29 USC § 216(b), Plaintiff, Civil Action No. 5:18-cv-1029-OLG v. COLT OILFIELD SERVICES, LLC, and ROY E. (EDDIE) AGUILAR, Defendant. UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY IN SUPPORT OF PLAINTIFFS' CORRECTED MOTION FOR NOTICE TO POTENTIAL PLAINTIFFS AND CONDITIONAL CERTIFICATION Plaintiffs file this Unopposed Motion to Extend Time to File Reply in Support of Plaintiffs' Corrected Motion for Notice to Potential Plaintiffs and Conditional Certification and in support show the Court the following: On December 9, 2018, Plaintiffs filed their Corrected Motion for Notice to Potential Plaintiffs and Conditional Certification ("Motion for Notice"). ECF 17. On December 17, 2018, the Court granted Defendants Motion to Extend Time to File Response to Plaintiffs' Motion for Notice, extending the deadline for Defendants to file their Response to the Motion for Notice until December 21, 2018. ECF 20. On December 21, 2018, Defendants filed their Response to Motion for Notice. ECF 22. Accordingly, Plaintiffs deadline to file their Reply in Support of the Motion for Notice is currently December 28, 2018. Plaintiffs request this extension due to their relative unavailability during the holidays and the Parties continued negotiations regarding a potential stipulation to notice that would alleviate any Stipulation on Notice and Conditional Certification need for Plaintiffs to file a Reply in Support of the Motion for Notice ("Reply"). Plaintiffs have conferred with Defendants and Defendants have indicated that they are unopposed to a one-week extension for Plaintiffs to file their Reply from December 28, 2018 until January 4, 2019. Accordingly, Plaintiffs respectively request that the Court grant this Motion and extend the deadline for Plaintiffs to file their Reply in Support of Motion for Notice from the current deadline of December 28, 2018 until January 11, 2019. Respectfully submitted, /s/ Jack Siegel JACK SIEGEL Attorney in Charge Texas Bar No. 24070621 SIEGEL LAW GROUP PLLC 2820 McKinnon, Suite 5009 Dallas, Texas 75201 Telephone: 214.790.4454 Email: jack@siegellawgroup.biz ATTORNEYS FOR PLAINTIFF Certificate of Conference Plaintiff's counsel conferred with Defense Counsel and Defense Counsel has indicated that they are unopposed to the extension requested by this Motion for the reasons provided above. /s/ Jack Siegel Jack Siegel Certificate of Service I hereby certify that the foregoing document was filed electronically through the Court's CM/ECF system in compliance with Local Rules on the date of this filing. /s/ Jack Siegel Jack Siegel Stipulation on Notice and Conditional Certification