Opinion
2:23-cv-01155-APG-DJA
08-08-2023
KAY AGUERO, Plaintiff, v. EXPERIAN INFORMATION SOLUTIONS, INC.; EQUIFAX INFORMATION SERVICES, LLC; SYNCHRONY FINANCIAL; FIRST SAVINGS BANK; KOHL'S INC.; AVANT, LLC; CAPITAL ONE BANK, NATIONAL ASSOCIATION; THE BANK OF MISSOURI; DISCOVER BANK; FIRST BANK & TRUST; AND COMENITY CAPITAL BANK, Defendants.
FREEDOM LAW FIRM Gerardo Avalos (w/permission) Gerardo Avalos Counsel for Plaintiff Marilea Ellis LEWIS ROCA ROTHGERBER CHRISTIE LLP Brittni Tanenbaum J Christopher Jorgensen Brittni A. Tanenbaum Counsel for Defendant Synchrony Bank
FREEDOM LAW FIRM
Gerardo Avalos (w/permission)
Gerardo Avalos
Counsel for Plaintiff Marilea Ellis
LEWIS ROCA ROTHGERBER CHRISTIE LLP
Brittni Tanenbaum
J Christopher Jorgensen
Brittni A. Tanenbaum
Counsel for Defendant Synchrony Bank
JOINT UNOPPOSED MOTION TO EXTEND DEADLINE FOR DEFENDANT SYNCHRONY BANK TO RESPOND TO COMPLAINT
Defendant Synchrony Bank (“Synchrony”) and Plaintiff Kay Aguero (“Plaintiff”), by counsel and pursuant to Federal Rule of Civil Procedure 6(b)(1)(A) and Local Rule IA 6-1, respectfully request this Court extend the deadline in which Synchrony has to answer or otherwise respond to Plaintiff's Complaint, through and until September 6, 2023. In support of this Motion, the parties stipulate as follows:
1. This is the first stipulation for extension of time for Synchrony to respond to Plaintiff's Complaint.
2. On July 21, 2023, Plaintiff filed a Complaint with this Court [ECF No. 1].
3. Synchrony's current deadline to respond to the Complaint is August 16, 2023.
4. In order to evaluate this matter and explore the possibility of early resolution with Plaintiff, counsel for Synchrony desires a twenty-one (21) day extension until September 6, 2023, to file a response to the Complaint.
5. Counsel for Synchrony conferred with Plaintiff's counsel regarding this requested extension, and Plaintiff's counsel has no objection.
6. The foregoing Motion is filed in good faith and not for dilatory or other improper purpose.
7. Plaintiff would not suffer any prejudice by the Court permitting Synchrony the requested extension of time and has consented to the requested extension.
8. Granting this Motion is in the interests of justice and is otherwise the right and proper thing to do.
ORDER
IT IS SO ORDERED.