Pearson v. Colt Oilfield Services, LLC et al

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

Unopposed MOTION for Leave to File Consents to Join by James Adkins, 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, Plaintiffs, v. COLT OILFIELD SERVICES, LLC, Case No. 5:18-cv-1029 TOTAL TANK, and ROY E. (EDDIE) AGUILAR, Defendants. MOTION FOR LEAVE TO FILE ADDITIONAL CONSENTS Plaintiffs respectfully move the Court for leave to file the Consents to Join for Rogelio Barron Jr. and Codey Brixey, copies of which are attached as Exhibits A and B, respectively. On January 15, 2019, the Court approved the Parties' Stipulation and Proposed Order Regarding Notice to Potential Plaintiffs. ECF 25. Pursuant to the Stipulation, the opt-in period for individuals to join this action would end forty-five days after Plaintiffs sent notice to potential plaintiffs. Id. Plaintiffs sent notice to the potential plaintiffs on February 26, 2019 and filed notice thereof with the Court on March 4, 2019. ECF 27. Therefore, the opt-in period closed on April 12, 2019. Rogelio Barron Jr. and Codey Brixey signed consent forms to participate in this action on July 17, 2019 and July 20, 2019, respectively. In the interest of judicial economy, rather than instituting a separate action for each individual, the Parties have agreed that Mr. Barron and Mr. Brixey should be included in the current case. The Parties have further agreed that the statute of limitations be tolled for the claims of each individual as of July 19, 2019, the date Defendant was notified of the claims. Counsel for Plaintiffs has conferred with counsel for Defendants, who do not oppose this motion. Respectfully submitted, /s/ Travis M. Hedgpeth Travis M. Hedgpeth Co-Attorney in Charge Texas Bar No. 24074386 THE HEDGPETH LAW FIRM, PC 3050 Post Oak Blvd., Suite 510 Houston, Texas 77056 Telephone: (281) 572-0727 Facsimile: (281) 572-0728 JACK SIEGEL Co-Attorney in Charge Texas Bar No. 24070621 Siegel Law Group PLLC 10440 N. Central Expy. Suite 1040 Dallas, Texas 75231 (214) 706-0834 phone (469) 339-0204 fax ATTORNEYS FOR PLAINTIFFS Certificate of Service I hereby certify that on August 21, 2019, the foregoing document was filed electronically through the Court's CM/ECF system in compliance with Local Rules. /s/ Travis M. Hedgpeth Travis M. Hedgpeth