Loding et al v. Sitel Operating Corporation

Filing 13

ORDER Granting 12 Stipulation to Extend Time. Sitel Operating Corporation answer due 5/30/2017. Signed by Magistrate Judge Carl W. Hoffman on 5/9/17. (Copies have been distributed pursuant to the NEF - ADR)

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Attorneys for Defendant
Sitel Operating Corporation

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Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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ANTHONY L. MARTIN
Nevada Bar No. 8177
[e-mail]
DANA B. SALMONSON
Nevada Bar No. 11180
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Wells Fargo Tower
Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]
Fax: [phone]

UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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BRANDI LODING AND TONSANIA
COLLINS, individually and on behalf of
others similarly situated,

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Plaintiffs,
vs.
SITEL OPERATING CORPORATION , a
Delaware Corporation

CASE NO.: 2:16-cv-02047-JAD-CWH
STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANT
SITEL OPERATING CORPORATION
TO RESPOND TO PLAINTIFFS’
COMPLAINT
(Third Request)

Defendant.

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Pursuant to LR IA 6-1, LR IA 6-2, and LR 7-1, Defendant, Sitel Operating Corporation
(“Sitel” or “Defendant”) by and through their undersigned counsel, Anthony L. Martin and Dana
B. Salmonson, of the law firm of Ogletree, Deakins, Nash, Smoak & Stewart, P.C., and Plaintiffs
Brandi Loding and Tonsania Collins (“Plaintiffs”), by and through their undersigned counsel, Don
Springmeyer and Bradley S. Schrager, of the law firm Wolf, Rifkin, Shapiro, Schulman, & Rabkin,
LLP, hereby agree to extend the time for Defendant to file a response to Plaintiff’s Complaint
twenty-two (22) days, as the twenty-first day falls on a holiday, up to and including May 30, 2017.
The present deadline is May 8, 2017.

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This is the parties’ third request for an extension of the response deadline. The parties first

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submitted a request to extend the response deadline on December 1, 2017 (ECF No. 8) because the

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parties were engaged in early settlement discussions and requested additional time to further

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discuss this matter. Further, the parties were working on the global resolution of two related

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matters filed in other jurisdictions - i.e. Gaffers v. Sitel Worldwide Corp. and Sitel Operating

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Corp., M.D. Tenn. Case No. 3:16-0128 and Adams v. Sitel Operation Corporation, M.D. N.C.

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Case No. 1:16-cv-01051. The request was granted on December 5, 2017. (ECF No. 9.)
The parties next submitted a request to extend the response deadline on February 6, 2017 in

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an effort to finalize mediation dates and continue their good faith discussions. (ECF No. 10.) The

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request was granted on February 7, 2017. (ECF No. 11.) Since that time, the parties have

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scheduled mediation for May 10, 2017.

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Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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As indicated in the parties’ first two requests to extend the response deadline, the parties

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have also entered into an agreement to voluntarily toll the statutes of limitation applicable to the

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claims of the named, opt-in, and putative Plaintiffs in these matters during the pendency of their

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discussions regarding potential resolution. Consequently, the parties are requesting an extension of

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time up to and including May 30, 2017 for Defendants to respond to Plaintiffs’ Complaint should

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this matter not resolve at the May 10, 2017 mediation.

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This request is being made to promote efficiency, the interests of justice, and judicial
economy and not for the purpose of undue delay.
IT IS SO STIPULATED:

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DATED this 8th day of May, 2017.

DATED this 8th day of May, 2017.

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SOMERS SCHWARTZ, P.C.

OGLETREE, DEAKINS, NASH, SMOAK
& STEWART, P.C.

/s/ Kevin J. Stoops
Kevin J. Stoops (admitted pro hac vice)
Jesse L. Young (pro hac admission pending)
Neil B. Pioch (pro hac admission pending)
One Town Square, Suite 1700
Southfield, MI 48076

/s/ Dana B. Salmonson
Anthony L. Martin
Nevada Bar No. 8177
Dana B. Salmonson
Nevada Bar No. 11180
Wells Fargo Tower
Suite 1500
3800 Howard Hughes Parkway
Las Vegas, NV 89169
Attorneys for Defendant Sitel Operating
Corporation

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WOLF, RIFKIN, SHAPIRO, SCHULMAN
& RABKIN, LLP

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Wells Fargo Tower
Suite 1500, 3800 Howard Hughes Parkway
Las Vegas, NV 89169
Telephone: [phone]

Ogletree, Deakins, Nash, Smoak & Stewart, P.C.

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Don Springmeyer
Nevada Bar No. 1021
Bradley S. Schrager
Nevada Bar No. 10217
3556 E. Russell Road, Second Floor
Las Vegas, NV 89120

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Attorneys for Plaintiffs Brandi Loding,
Tonsania Collins individually and on behalf
of others similarly situated

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ORDER

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IT IS SO ORDERED.
May 9, 2017
May 9, 2017
UNITED STATES DISTRICT COURT JUDGE

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DATED
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29741167.1

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