Opinion
2:22-CV-01387-JCM-NJK
10-17-2022
WRIGHT, FINLAY & ZAK, LLP FREEDOM LAW FIRM Ramir M. Hernandez, Esq. Nevada Bar No. 13146 Gerardo Avalos, Esq. Nevada Bar No. 15171 Attorneys for Defendant, 2233 Paradise Road, LLC dba Cash Factory USA Attorneys for Plaintiff, Jimmy Eason Jr.
WRIGHT, FINLAY & ZAK, LLP
FREEDOM LAW FIRM
Ramir M. Hernandez, Esq. Nevada Bar No. 13146
Gerardo Avalos, Esq. Nevada Bar No. 15171
Attorneys for Defendant, 2233 Paradise Road, LLC dba Cash Factory USA
Attorneys for Plaintiff, Jimmy Eason Jr.
JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT (SECOND REQUEST)
Plaintiff, Jimmy Eason Jr. (“Plaintiff”), and Defendant, 2233 Paradise Road, LLC dba Cash Factory USA (“Cash Factory USA”) (collectively “Parties”), by and through their counsel of record, hereby move as follows:
On August 25, 2022, Plaintiff filed his Complaint [ECF No. 1]. Cash Factory USA was served with Plaintiff's Complaint on August 26, 2022. The original deadline for Cash Factory USA to respond to Plaintiff's Complaint was September 16, 2022. On September 19, 2022, the Court granted Cash Factory USA's Joint Stipulation for Extension of Time for Defendant to file Answer, which set October 14, 2022, as the new deadline [ECF No. 7]. The Parties have discussed extending the deadline for Cash Factory USA to respond to Plaintiff's 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 Cash Factory USA to file their responsive pleading to Plaintiff's Complaint to November 14, 2022.
This is the second motion for an extension of time for Cash Factory USA to file their responsive pleading. Cash Factory USA has just acquired new counsel that needs the additional time to review the facts and allegation in this case. Moreover, the parties are actively discussing settlement. In the event the parties cannot resolve the case, it is anticipated that they will stipulate to remove the case to arbitration. 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, Cash Factory USA agrees to participate in any Rule 26(f) conference that occurs during the pendency of this extension.
IT IS SO ORDERED: