Taylor v. C6 Disposal Systems, Inc.

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

ADVISORY TO THE COURT by Charles Taylor.

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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 JOINT ADVISORY TO THE COURT Plaintiff Charles Taylor and C6 Disposal Systems, Inc. (collectively, "the Parties") file this Joint Advisory with the Court regarding the issuance of Notice to the Putative Class Members. The Parties have agreed to the form and content of the Proposed Notice and Consent Form, and it is attached as Exhibit A. The Parties further agree on the following schedule to control the opt-in period. DEADLINE SUBJECT Defendant to disclose the names and last- known addresses, e-mail addresses, telephone numbers, and dates of employment of the Putative Class Members in a usable electronic 14 Days from Order Approving Final Notice format. Plaintiff acknowledges telephone to Putative Class Members numbers will not be used to communicate with putative class members, and instead will only be used to contact a class member after he or she has provided a signed consent. Plaintiff's counsel shall send by mail and e-mail, the Court-approved Notice and Consent Form to the Putative Class Members. 21 Days from Order Approving Notice to Putative Class Members Defendant shall post a copy of the Notice and Consent Form in a conspicuous location at its San Antonio, Texas office. The Putative Class Members shall have 60 days to return their signed Consent forms for filing 60 Days from Notice is Mailed to Putative with the Court. Class Members Defendant may take down the posted Notice and Consent Form. Plaintiff's Counsel is authorized to send by mail and e-mail a second identical copy of the 30 Days from Notice is Mailed to Putative Notice/Consent Form to the Putative Class Class Members Members reminding them of the deadline for the submission of the Consent forms. Date: August 30, 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 Plaintiffs 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 CERTIFICATE OF SERVICE I hereby certify that on August 30, 2019, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Southern 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