Case 4:17-cv-00642-ALM-KPJ Document 28 Filed 12/04/17 Page 1 of 17 PageID #: 330
UNITED STATES DISTRICT COURT Eastern District of Texas Sherman Division § § § § § § § § § §
David Dickens, individually and on behalf of all those similarly situated Plaintiff, v. J. G. Wentworth Home Lending LLC, Defendant
CA No: 4:17-cv-642-ALM-KPJ Jury Demanded
Plaintiff’s Motion for Notice to Potential Plaintiffs and Conditional Certification Plaintiff David Dickens (“Plaintiff” or “Dickens”), individually and on behalf of other similarly-situated current and former loan officers (“Potential Plaintiffs” or “Class Members”) including Andrew Robinson and Robert Staab employed by Defendant J. G. Wentworth Home Lending, LLC and its predecessor Weststar Mortgage, Inc.1 (“Defendant” or “JGWHL”), hereby files this Motion for Notice to Potential Plaintiffs and Conditional Certification (the “Motion”) and moves this Court for an order granting conditional certification of Plaintiff’s collective action claims. Plaintiff easily meets the lenient conditional certification standard. I.
OVERVIEW
The illegal compensation policy of Defendant’s Loan Officers is set forth in writing in an Exhibit to each Loan Officer’s Compensation and Employment Agreement. That Policy is attached hereto as Exhibit A. Pursuant to the written policy, if the Loan Officers’ commission for
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J.G. Wentworth Home Lending, LLC bought Weststar Mortgage, Inc. during the three years preceding this action. _______________________________________________________________________________ Plaintiff’s Motion for Notice and Conditional Certification Page | 1