Opinion
2:21-cv-01078-JCM-VCF
04-17-2023
SKANE MILLS LLP By: Elizabeth A. Skane, Esq. (NSBN 7181) Sarai L. Brown, Esq. (NSBN 11067) Patrice Stephenson-Johnson (NSBN 12283) Attorneys for Plaintiffs Brighthouse Life Insurance Company and Brighthouse Securities, LLC Rory T. Kay, Esq. (NSBN 12416) Tara U. Teegarden, Esq. (NSBN 15344) McDONALD CARANO LLP Paula D. Shaffner, Esq. (Admitted Pro Hac Vice) Amy E. Sparrow, Esq. (Admitted Pro Hac Vice) Stradley Ronon Stevens & Young, LLP Attorneys for Defendant Lincoln Financial Advisors Corporation
SKANE MILLS LLP By: Elizabeth A. Skane, Esq. (NSBN 7181) Sarai L. Brown, Esq. (NSBN 11067) Patrice Stephenson-Johnson (NSBN 12283) Attorneys for Plaintiffs Brighthouse Life Insurance Company and Brighthouse Securities, LLC
Rory T. Kay, Esq. (NSBN 12416) Tara U. Teegarden, Esq. (NSBN 15344) McDONALD CARANO LLP Paula D. Shaffner, Esq. (Admitted Pro Hac Vice) Amy E. Sparrow, Esq. (Admitted Pro Hac Vice) Stradley Ronon Stevens & Young, LLP Attorneys for Defendant Lincoln Financial Advisors Corporation
STIPULATION AND ORDER TO EXTEND DEADLINE FOR LINCOLN FINANCIAL ADVISORS CORPORATION TO FILE RESPONSIVE PLEADING TO COMPLAINT
[First Request]
Under Local Rules IA 6-1 and 7-1, Defendant Lincoln Financial Advisors Corporation (“LFA”) and Plaintiffs Brighthouse Life Insurance Company and Brighthouse Securities, LLC (collectively “Plaintiffs”), by and through their attorneys, hereby stipulate and request that the Court extend the deadline for LFA to file its responsive pleading to Plaintiffs' First Amended Complaint (“FAC”) from April 14, 2023, up to and including May 3, 2023.
In support of this Stipulation, the parties state as follows:
1. On June 7, 2021, Plaintiffs filed their Complaint asserting claims against LFA, among others. [ECF No. 1].
2. Plaintiffs amended their complaint on November 24, 2021. [ECF No. 15].
3. On November 30, 2021, LFA moved to dismiss Plaintiffs' FAC under FRCP 12(b)(1) and 12(b)(6). [ECF No. 20].
4. Plaintiffs filed their Opposition to LFA's Motion to Dismiss Plaintiffs' FAC on February 4, 2022. [ECF No. 31].
5. On February 25, 2022, LFA filed its reply in support of its Motion to Dismiss Plaintiffs' FAC. [ECF No. 37].
6. On March 31, 2023, this Court entered an order granting in part, and denying in part, LFA's Motion to Dismiss Plaintiffs' FAC (“Order”). [ECF No. 52].
7. The Court's March 31, 2023 Order triggered LFA's 14-day deadline to file its responsive pleading to Plaintiffs' FAC.
8. LFA's counsel needs additional time to investigate and prepare an appropriate response to Plaintiffs' remaining claims.
9. This is LFA's first request to this Court for an extension of time to respond to Plaintiffs' FAC, the request is in good faith and not for the purposes of delay, and the requested extension will not prejudice any party.
10. The parties stipulate and request that the Court extend the deadline for LFA to file its responsive pleading to Plaintiffs' First Amended Complaint from April 14, 2023, up to and including May 3, 2023.
IT IS SO ORDERED.