Opinion
CASE NO. 3:11-cv-519
03-06-2013
VONDA NOEL, On behalf of HERSELF and All Others Similarly Situated, Plaintiff, v. METROPOLITAN GOVERNMENT OF NASHVILLE AND DAVIDSON COUNTY, TENNESSEE, Defendant.
CLASS AND COLLECTIVE
ACTION
JUDGE SHARP
MAGISTRATE JUDGE KNOWLES
MOTION FOR LEAVE TO FILE SUR-REPLY IN OPPOSITION TO
DEFENDANT'S MOTION TO DECERTIFY COLLECTIVE ACTION
In Defendant's Reply to Plaintiff's Response to Defendant's Motion to Decertify the Collective Class (Doc. No. 160.), Defendant focuses, for the first time, on Defendant's claim that it pays a "salary" to its correctional officers for all regularly scheduled work, rather than paying for the shifts actually worked.
To address this newly framed argument, Plaintiff respectfully requests leave to file the attached, two-page Sur-Reply.
Respectfully submitted,
_______________
GEORGE E. BARRETT
DAVID W. GARRISON
SCOTT P. TIFT
SETH M. HYATT
BARRETT JOHNSTON, LLC
217 Second Avenue North
Nashville, TN 37201
(615) 244-2202
gbarrett@barrettj ohnston.com
dgarrison@barrettj ohnston.com