Opinion
2:22-cv-02162-JCM-EJY
01-26-2023
CHAD BETTS, Plaintiff, v. CLARITY SERVICES, INC., EXPERIAN INFORMATION SOLUTIONS, INC., FAY SERVICING, LLC, Defendants.
WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez Ramir M. Hernandez, Esq. Nevada Bar No. 13146 Attorneys for Defendant, Fay Servicing, LLC FREEDOM LAW FIRM Gerardo Avalos Gerardo Avalos, Esq. Nevada Bar No. 15171 Attorneys for Plaintiff, Chad Betts
WRIGHT, FINLAY & ZAK, LLP
Ramir M. Hernandez
Ramir M. Hernandez, Esq.
Nevada Bar No. 13146
Attorneys for Defendant, Fay Servicing, LLC
FREEDOM LAW FIRM
Gerardo Avalos
Gerardo Avalos, Esq.
Nevada Bar No. 15171
Attorneys for Plaintiff, Chad Betts
JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT (FIRST REQUEST)
Plaintiff, Chad Betts (“Plaintiff”), and Defendant, Fay Servicing, LLC (“Defendant”) (collectively “Parties”), by and through their counsel of record, hereby stipulate and agree as follows:
On January 18, 2023, Plaintiff filed his First Amended Complaint [ECF No. 4]. Defendant was served with Plaintiff's First Amended Complaint on January 23, 2023. The deadline for Defendant to respond to Plaintiff's First Amended Complaint is February 13, 2023. The Parties have discussed extending the deadline for Defendant to respond to Plaintiff's First Amended Complaint to allow for better investigation of the allegations and discuss possible resolution of the matter.
WHEREAS, the Parties hereby stipulate and agree to extend the deadline for Defendant to file its responsive pleading to Plaintiff's First Amended Complaint to March 15, 2023.
This is the first motion for an extension of time for Defendant to file its responsive pleading. The extension is requested in good faith and is not for purposes of delay or prejudice to any other party.
As part of this motion, Defendant agrees to participate in any Rule 26(f) conference that occurs during the pendency of this extension.
IT IS SO ORDERED: