As we look forward to Spring Training, the Fourth Circuit recently analyzed what courts sometimes refer to as “picking off” collective action plaintiffs.   In Simmons v. United Mortgage Co.pdf., ___F.3d____No. 09-2147, 2011 WL 184356 (Jan. 21, 2011), the Court discussed the interplay of FLSA collective action procedure, Federal Rule of Civil Procedure 68 offers of … Continue Reading