The delay was the product of an inadvertent internal calendaring error (this is not the first time in this case the defense has cmade this claim for missing a dead line see not neglect of the matter or any tactical purpose

and it caused Plaintiff no prejudice

contemporaneously with the opposition, Mr. Patel served complete answers and objections to all 
five interrogatories the very relief the Motion to Compel seeks (is false, the motion to compel seeks waived objections as frcp states the plaintiff is entitled to and dening the plaintiff what he has earned is prejudice)

The short delay was inadvertent
occurred while the briefing of three pending dispositive motions, including the Individual Defendants’ Motion to Dismiss (Dkt. 117)
dkt 26
page 2 item 6:
"Due to an inadvertent omission, however, Defendants’ Joint Motion to Dismiss was not served by electronic mail, facsimile transmission and/or U.S. First Class mail on February 17, 2026."

dkt 33
page 2 item 3:
"Due to technical issues with his PACER account on March 16, 2026, Mr. Wangsgard was unable to access the filing system for the United States District Court for the Northern District 
of Oklahoma to file the required Entry of Appearance on behalf of Defendants; those issues have now been resolved."

dkt 33 
page 2 item 4:
"Due to scrivener’s error, Mr. Wangsgard’s name was not removed from the opening paragraph of Defendants’ Response to Plaintiff’s Motion to Strike Defendants’ Joint Motion 
(Doc. 26) as was intended and as it had been removed from the signature line of the Response."

dkt 46
page 4 para 2 sentence 1:
"Defendants' failure to timely answer resulted from an inadvertent docketeting error, not from any intention to disregard the Court or the Plaintiff."

dkt 46
page 4 para 2 sentence 4:
Defendants counsel failed to calendar a response deadline after those amended affidavits were filed."

dkt 46
page 4 para 2 sentence 5:
"That failure was inadvertent"

dkt 57
page 2 para 2 sentence 3:
"The failure to answer was inadvertent rather than willful, evidenced by Defendants’ continuous defense through responsive pleadings, and ongoing "adherence to this Court’s orders."
dkt 57
page 5 para 2 sentence 1:
"Defendants’ failure to timely answer resulted from an inadvertent calendaring error, not from any intention to disregard the Court or the Plaintiff."

dkt 57
page 5 para 2 sentence 4:
"Defendants’ counsel failed to calendar a response deadline after those amended affidavits were filed."
(the issue is with the defense counsel, since the defendants do not draft nor file their own briefs an d pleadings)

dkt 57
page 5 para 3 sentence 1:
"There is no pattern of delay or indifference here. This is the first pleading deadline Defendants missed, and the circumstances that caused the miss were not of Defendants’ own 
making."

dkt 81
page 1 para 2 sentence 3
". Rather, the delay resulted from counsel's inadvertent miscalculation of the applicable response deadline following the Court's May 14, 2026, Order."

dkt 81
page 3 item 11:
Rather, the default resulted from counsel's inadvertent miscalculation of the 
response deadline following the Court's May 14, 2026, Order

dkt 82
page 2 item 5:
The one-day delay resulted from counsel's inadvertent miscalculation of the response deadline and was not the result of bad faith, willful disregard of the Court's orders, or 
dilatory conduct. 

Now comes dkt 138
page 1 para 2 sentence 2
" The delay was the product of an inadvertent internal calendaring error,..."

mr Mendoza claims no prejudice to plaintiff, that no witnesses ar lost yet defendants has fired plaintiff former co-worker laura the individual at center of the hostile work environment, sexual harassment claim making her unavailable for deposition, interrogatory and other discovery tools, defendants has not produced the front desk communication log after eeoc request, after rfp request, after discovery rfp motion to compel, while the defense counsel other very clients state in responses to discovery they do not kno what the front desk communication log is. defendant have not verified preservation efforts have been in place to protect this evidence after request to do so from plaintiff. the motion to compel is purely about protecting plaintiff core case by use of frcp which state is a defendants served with written discovery has not responded within 30 days have waive right to oject. defendants late responses should be denied and forced compliance with frcp by wainvng those objections. the cust of defendant patl dkt 138 is to somehow magically reinstate those right by seving 66 days late response with those objections and that is why dkt 138 should be denied and dkt 136 should be granted ordering the defendant to supply un objected answers,