Taylor v. C6 Disposal Systems, Inc.

Western District of Texas, txwd-5:2019-cv-00347

ADR Report Filed - Joint Report on Alternative Report Resolution and Request to Extend the Demand Deadline by Charles Taylor, C6 Disposal Systems, Inc. Modified on 11/27/2019, to add filer

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION CHARLES TAYLOR, § Individually and on behalf § Civil Action No. 5:19-cv-00347-ESC of all others similarly situated § § Plaintiff § JURY TRIAL DEMANDED § v. § COLLECTIVE ACTION § PURSUANT TO 29 U.S.C. § 216(b) C6 DISPOSAL SYSTEMS, INC. § § CLASS ACTION PURSUANT TO Defendant § FED. R. CIV. P. 23 PARTIES' JOINT REPORT ON ALTERNATIVE DISPUTE RESOLUTION AND REQUEST TO EXTEND THE DEMAND DEADLINE Plaintiff Charles Taylor and Defendant C6 Disposal Systems, Inc. (collectively, "the Parties") hereby file this Joint Report on Alternative Dispute Resolution and Request to Extend the Demand Deadline, in accordance with Local Rule of Civil Procedure 88(b) and this Court's Scheduling Order, ECF No. 35. The opt-in period in this matter closed on November 19, 2019. To date, twenty-eight (28) individuals have filed their consent forms to be party plaintiffs in this matter. The Parties have discussed participating in formal mediation before an experienced wage and hour mediator.1 Plaintiff, Charles Taylor, through his counsel of record, and Defendant C6 Disposal Systems, Inc. though Jorge Cantu and its counsel of record, are the individuals responsible for settlement negotiations. The Parties anticipate mediating this matter before February 13, 2020. 1 The Parties have not yet agreed to a mediator but anticipate that each party will equally split the cost of the mediation. Page 1 This Court's Scheduling Order further requires that each party asserting affirmative claims provide a demand by Friday, November 29, 2019. The Parties respectfully request to continue this deadline to allow them to compile the necessary documentation to make meaningful demands and participate in mediation. Plaintiff Charles Taylor and Defendant C6 Disposal Systems, Inc. respectfully request that this Court extend the deadline by which they are required to exchange demands to run concurrently with the deadline this Court sets for the parties to mediate this matter, if any. Page 2 Date: November 27, 2019 Respectfully submitted, ANDERSON ALEXANDER, PLLC By: /s/ Clif Alexander Clif Alexander Texas Bar No. 24064805 clif@a2xlaw.com Lauren E. Braddy Texas Bar No. 24071993 lauren@a2xlaw.com Alan Clifton Gordon Texas Bar No. 00793838 cgordon@a2xlaw.com Carter T. Hastings Texas Bar No. 24101879 carter@a2xlaw.com 819 N. Upper Broadway Corpus Christi, Texas 78401 Telephone: (361) 452-1279 Facsimile: (361) 452-1284 Attorneys for Plaintiff and the Putative Class Members Clausewitz Law Firm By: /s/Tiffanie S. Clausewitz Tiffanie S. Clausewitz State Bar No. 24051936 tiffanie@clausewitzlaw.com Shellie R. Reyes State Bar No. 24082115 shellie@clausewitzlaw.com 2722 West Bitters Road, Suite 110 San Antonio, Texas 78248 Telephone: (210) 762-6422 Facsimile: (210) 762-6988 Attorneys for Defendant Page 3 CERTIFICATE OF SERVICE I hereby certify that on November 27, 2019, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Western District of Texas, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means. /s/ Clif Alexander Clif Alexander Page 4