Clark et al v. Bank of America Corporation

Filing 67

ORDER Granting #66 Stipulation to Extend Time for Parties to Re-Submit Proposed Notice and Consent-To-Sue Forms. The Parties will have until 4/22/19 to resubmit the proposed notice and consent-to-sue forms. Signed by Chief Judge Gloria M. Navarro on 4/15/2019. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02228-GMN-VCF Document 66 Filed 04/15/19 Page 1 of 4

Sheri M. Thome
1 Nevada Bar No. 8657
Chad C. Butterfield
2 Nevada Bar No. 10532
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
3 300 South 4th Street, 11th Floor,
Las Vegas, NV 89101
4 Telephone: [phone]
Facsimile: 702.727.1401
5
Michael D. Mandel (admitted pro hac vice)
6 (California SBN #216934)
John A. Van Hook SBN (pro hac vice)
7 (California SBN #205067)
MCGUIREWOODS LLP
8 1800 Century Park East
8th Floor
9 Los Angeles, CA 90067-1501
Telephone: [phone]
10 Facsimile: 310.315.8210
11 Attorneys for Defendant
BANK OF AMERICA, N.A.
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(Additional counsel appear on following page)
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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17 MAUREEN CLARK and SONYA
ALEXANDER, individually, and on behalf of
18 all others similarly situated,
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Plaintiff,

STIPULATION TO EXTEND TIME FOR
PARTIES TO RE-SUBMIT PROPOSED
NOTICE AND CONSENT-TO-SUE
FORMS

vs.

21 BANK OF AMERICA CORPORATION,
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CASE NO. 2:16-cv-02228-GMN-VCF

Complaint Filed:

September 21, 2016

Defendant.

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STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TOSUE FORMS

Case 2:16-cv-02228-GMN-VCF Document 66 Filed 04/15/19 Page 2 of 4

Don Springmeyer
1 Nevada Bar No. 1021
Bradley S. Schrager
2 Nevada Bar No 10217
WOLF, RIFKIN, SHAPIRO, SCHULMAN & RABKIN, LLP
3 3556 E. Russell Road, Second Floor
Las Vegas, Nevada 89120
4 Telephone: [phone]
Facsimile: 702.341.5300
5 [e-mail]
[e-mail]
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7 Kevin J. Stoops (admitted pro hac vice)
(Michigan SBN # P64371)
8 SOMMERS SCHWARTZ, P.C.
One Towne Square, 17th Floor
9 Southfield, Michigan 48076
10 Telephone: [phone]
Facsimile: 248.936.2143
11 [e-mail]
12 Jason T. Brown (admitted pro hac vice)
(New Jersey SBN# 035921996)
13 Nicholas Conlon (admitted pro hac vice)
(New Jersey SBN# 034052013)
14
BROWN, LLC
15 111 Town Square Place, Suite 400
Jersey City, NJ 07310
16 Telephone: [phone]
[e-mail]
17 [e-mail]
18 Attorneys for Plaintiffs MAUREEN CLARK and
SONYA ALEXANDER
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84781847.1

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STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TOSUE FORMS

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RECITALS
On September 21, 2016, Plaintiffs MAUREEN CLARK and SONYA ALEXANDER

3 (“Plaintiffs”) filed a putative class and collective action complaint in the United States District
4 Court, District of Nevada (Dkt. #1);
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On June 22, 2018, Plaintiffs filed their Second Amended Class and Collective Complaint

6 (Dkt. #52);
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On March 31, 2019, the Court granted Plaintiffs’ Pre-Discovery Motion for Conditional

8 Certification Pursuant to 29 U.S.C. § 216(b) and ordered the parties to meet and confer to correct
9 certain deficiencies the Court identified in Plaintiffs’ proposed notice to putative collective
10 members, and to resubmit the proposed notice and consent-to-sue forms for the Court’s approval
11 within fourteen days, which falls on the pressent date of April 15, 2019 (Dkt. #65);
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The Parties have met and conferred to prepare revised proposed notice and consent-to-sue

13 forms, but have not yet agreed upon final versions for submission to the Court. The Parties are
14 confident that if given seven (7) more days to confer, they will reach an agreement on revised
15 documents to file for the Court’s aproval;
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STIPULATION
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between

18 Plaintiffs and Defendant, through their respective undersigned counsel of record, that:
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1. The Parties will have until April 22, 2019 to resubmit the proposed notice and consentto-sue forms for the Court’s approval, an extension of 7 days;
IT IS SO STIPULATED.

22 DATED: April 15, 2019
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WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP

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By:

/s/ Don Springmeyer
Don Springmeyer, Esq.

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Attorneys for Plaintiffs
MAUREEN CLARK and SONYA
ALEXANDER

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STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TOSUE FORMS

1 DATED: April 15, 2019
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MCGUIREWOODS LLP
By: _____/s John Van Hook______________________
Michael D. Mandel, Esq.
John A. Van Hook, Esq.

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Attorneys for Defendant
BANK OF AMERICA, N.A.

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CERTIFICATE OF SERVICE

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I hereby certify that on this 15th day of April, 2019, a true and correct copy
of STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED
NOTICE AND CONSENT-TO-SUE FORMS; was served via the United States District Court
CM/ECF system on all parties or persons requiring notice.
By /s/ Christie Rehfeld
Christie Rehfeld, an Employee of
WOLF, RIFKIN, SHAPIRO, SCHULMAN &
RABKIN, LLP

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STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT PROPOSED NOTICE AND CONSENT-TOSUE FORMS

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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4 MAUREEN CLARK and SONYA
ALEXANDER, individually, and on behalf of
5 all others similarly situated,
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CASE NO. 2:16-cv-02228- GMN-VCF
[PROPOSED] ORDER GRANTING
STIPULATION TO EXTEND TIME FOR
PARTIES TO RE-SUBMIT PROPOSED
NOTICE AND CONSENT-TO-SUE
FORMS

Plaintiff,
vs.

8 BANK OF AMERICA CORPORATION,
9

Defendant.

Complaint Filed:

September 21, 2016

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[PROPOSED] ORDER
Based on the Stipulation of the Parties and good cause appearing, the Court hereby

13 GRANTS the Parties’ Stipulation to Extent Time to Re-submit Proposed Notice and Consent-to14 Sue Forms, and Orders as follows:
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1. The Parties will have until April 22, 2019 to resubmit the proposed notice and consentto-sue forms for the Court’s approval, an extension of 7 days;

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IT IS SO ORDERED.
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DATED this _____ day of April, 2019.

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Gloria M. Navarro, Chief Judge
UNITED STATES DISTRICT COURT

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94341043.1

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[PROPOSED] ORDER GRANTING STIPULATION TO EXTEND TIME FOR PARTIES TO RE-SUBMIT
PROPOSED NOTICE AND CONSENT-TO-SUE FORMS