Opinion
2:22-cv-01604-GMN-DJA
11-23-2022
MARGARITA CARRERA, Plaintiff, v. ALLIED COLLECTION SERVICES, INC., Defendant.
SEAN P. FLYNN (SBN: 15408) DANIEL A. MANN (SBN: 15594) GORDON REES SCULLY MANSUKHANI, LLP Attorney for Defendant ALLIED COLLECTION SERVICES, INC. Fair Collections & Outsourcing, Inc. FREEDOM LAW FIRM, LLC George H. Haines Gerardo Avalos Attorneys for Plaintiff Margarita Carrera
Complaint Filed: September 21, 2022
Current Response Date: October 27, 2022
Proposed New Response Date: December 16, 2022
SEAN P. FLYNN (SBN: 15408)
DANIEL A. MANN (SBN: 15594)
GORDON REES SCULLY MANSUKHANI, LLP
Attorney for Defendant
ALLIED COLLECTION SERVICES, INC.
Fair Collections & Outsourcing, Inc.
FREEDOM LAW FIRM, LLC
George H. Haines
Gerardo Avalos
Attorneys for Plaintiff
Margarita Carrera
STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFFS' COMPLAINT BEYOND 30 DAYS
DANIEL J. ALBREGTS, UNITED STATES MAGISTRATE JUDGE
Counsel for Defendant, Allied Collection Services, Inc. (“Defendant”), and Counsel for Plaintiff, Margarita Carrera (hereinafter “Plaintiff”), hereby stipulate to extend the time for Defendant to respond to Plaintiff's Complaint, filed on September 21, 2022 and served on Defendant on September 27, 2022. The Parties are actively engaged in ongoing negotiations to resolve this matter and believe an additional fifty (50) days would adequately facilitate the negotiations.
Defendant's response was due on October 27, 2022. Therefore, the Parties request Defendant's deadline be extended by an additional fifty (50) days to December 16, 2022.
This is the Parties first request for a court order extending time for Defendant to respond to the Complaint. This request is made in good faith, and is not being made to delay these proceedings. Moreover, as stated above, the requested additional time may help facilitate settlement negotiations.
The court notes that the parties did not cite excusable neglect for missing their original deadline to respond to the complaint as required by Local Rule IA 6-1(a). Nonetheless, the parties assert that they are in the process of negotiating a resolution to this matter. In the interest of promoting that resolution, IT IS THEREFORE ORDERED that the parties' stipulation to extend time (ECF No. 5) is GRANTED. The parties are reminded to closely follow the Local Rules in seeking any future extensions.