Opinion
2:22-cv-01645-JAD-EJY
10-25-2022
AMANDA DAVIS, individually and on behalf of all others similarly situated, Plaintiff, v. AMERICAN EDUCATION SERVICES LLC; KEYCORP FINANCIAL, INC. dba KEYBANK, Defendants.
Patrick J. Reilly, Esq. Monique S. Jammer, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Amanda Davis Attorneys for American Education Services LLC
Patrick J. Reilly, Esq. Monique S. Jammer, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP
George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Amanda Davis Attorneys for American Education Services LLC
STIPULATION AND ORDER TO EXTEND DEADLINE TO RESPOND TO COMPLAINT
(First Request)
STIPULATION
Plaintiff Amanda Davis (“Plaintiff”), by and through her counsel of record, George Haines, Esq., of Freedom Law Firm, and, Defendant American Education Services LLC (“AES”), by and through its counsel of record, Patrick J. Reilly, Esq., of the law firm of Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree as follows:
1. On September 28, 2022, Plaintiff filed her Complaint For Damages (the “Complaint”). ECF No. 1.
2. On or about October 3, 2022, Plaintiff served the Summons and Complaint on AES.
3. The current deadline for AES to respond to Plaintiff's Complaint was October 24, 2022.
4. Plaintiff has agreed to grant an extension for AES to answer, or otherwise plead in response to the Complaint, to allow the parties to investigate the matter and discuss potential resolution.
5. AES shall have up to, and including, November 7, 2022, in which to answer or otherwise plead in response to Plaintiff's Complaint.
6. This stipulation is one day late. Though Plaintiff's counsel had agreed informally to a stipulation to extend this deadline, counsel for AES was unable to obtain approval on the form of stipulation until the morning of October 25, 2022. Counsel apologizes to the Court for this delay.
7. This stipulation is brought in good faith by all parties and not for purposes of delay. This extension will not result in any undue delay in the administration of this case.
8. This is the first request for extension of time requested by the parties with respect to responding to the Complaint.
ORDER
IT IS SO ORDERED.