Opinion
Case No. 2:13-cv-00225-MMD-VCF
03-19-2013
TIM TOTH, Plaintiff, v. NCO FINANCIAL SYSTEMS, INC., and DOES 1-10, inclusive, Defendant.
SHANNON G. SPLAINE, ESQ. Nevada Bar No. 8241 LINCOLN, GUSTAFSON & CERCOS ATTORNEYS AT LAW Attorneys for Defendant, NCO FINANCIAL SYSTEMS, INC.
SHANNON G. SPLAINE, ESQ.
Nevada Bar No. 8241
LINCOLN, GUSTAFSON & CERCOS
ATTORNEYS AT LAW
Attorneys for Defendant, NCO FINANCIAL SYSTEMS, INC.
DEFENDANT NCO FINANCIAL
SYSTEMS, INC.'S UNOPPOSED
MOTION FOR EXTENSION OF TIME
TO RESPOND TO COMPLAINT
DEFENDANT NCO FINANCIAL SYSTEMS, INC.'S UNOPPOSED MOTION
FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Defendant, NCO Financial Systems, Inc. (NCO), through counsel and under the Federal Rules of Civil procedure, files this Unopposed Motion for an Extension of Time to Respond to Complaint, and states:
1. On February 26, 2013, Plaintiff, Tim Toth (Plaintiff), served his complaint and summons on NCO. NCO's responsive pleading is due on March 18, 2013.
2. Undersigned counsel, however, requests additional time to review the file materials, conduct an investigation and confer with her client in order to draft an appropriate responsive pleading. In addition, the extension will allow the parties the time necessary to engage in meaningful and good-faith settlement negotiations in hopes the parties can reach a mutually agreeable resolution without the Court's involvement.
3. Plaintiff, through counsel, has agreed to allow NCO an extension of time through and including April 2, 2013 to respond to the complaint.
WHEREFORE, Defendant, NCO Financial Systems, Inc., respectfully requests this Court grant it an extension through and including April 2, 2013, to respond to the complaint, and for such other relief as this Court deems proper.
Respectfully submitted,
LINCOLN, GUSTAFSON & CERCOS
_______________
Shannon B. Splaine, Esq.
Nevada Bar No. 8241
3960 Howard Hughes Parkway
Suite 200
Las Vegas, NV 89169-5968
Telephone: (702) 257-1997
Facsimile: (702) 257-2203
ssplaine@lgclawoffice.com
Attorneys for Defendant,
NCO FINANCIAL SYSTEMS, INC.
CERTIFICATE OF SERVICE
I certify that on this 18th day of March, 2013, a copy of the foregoing was filed electronically in the ECF system. Notice of this filing will be sent to the parties of record by operation of the Court's electronic filing system, including Plaintiff's counsel as described below. Parties may access this filing through the Court's system.
George Haines, Esq.
Haines & Krieger, LLC
5041 N. Rainbow Boulevard
Las Vegas, NV 89130
IT IS SO ORDERED.
______________________________
UNITED STATES MAGISTRATE JUDGE