Opinion
2:23-cv-00354-CDS-VCF
04-04-2023
Marilea Ellis, Plaintiff, v. Equifax Information Services, LLC; Experian Information Solutions, Inc.; National Consumer Telecom & Utilities Exchange, Inc.; Comenity Capital Bank N.A.; Petal Card, Inc.; Synchrony Financial; First Premier Bank dba Premier Bankcard, LLC; TD Bank USA; and Citigroup Financial Products, Inc., dba Citibanks CBNA, Defendants.
LIPSON NEILSON P.C. Joseph P. Garin Janeen V. Isaacson Attorneys for Defendant Comenity Capital Bank N.A. FREEDOM LAW FIRM, LLC Gerardo Avalos Attorney for Plaintiff Marilea Ellis George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM, LLC Attorneys for Plaintiff Marilea Ellis Brittni A. Tanenbaum, Esq. LEWIS ROCA ROTHGERBER CHRISTIE Attorneys for Synchrony Financial Madeleine Coles, Esq. BALLARD SPAHR LLP Attorneys for Citigroup Financial Products, Inc. dba Citibanks CBNA Gia Marina, Esq. CLARK HILL PLC Attorneys for Equifax Information Services, LLC; Experian Information Solutions, Inc.; and National Consumer Telecom & Utilities Exchange, Inc. Loren S. Young, Esq. LINCOLN, GUSTAFSON & CERCOS Attorneys for TD Bank USA, N.A.
LIPSON NEILSON P.C.
Joseph P. Garin
Janeen V. Isaacson
Attorneys for Defendant Comenity Capital Bank N.A.
FREEDOM LAW FIRM, LLC
Gerardo Avalos
Attorney for Plaintiff Marilea Ellis
George Haines, Esq.
Gerardo Avalos, Esq.
FREEDOM LAW FIRM, LLC
Attorneys for Plaintiff Marilea Ellis
Brittni A. Tanenbaum, Esq.
LEWIS ROCA ROTHGERBER CHRISTIE
Attorneys for Synchrony Financial
Madeleine Coles, Esq.
BALLARD SPAHR LLP
Attorneys for Citigroup Financial Products, Inc. dba Citibanks CBNA
Gia Marina, Esq.
CLARK HILL PLC
Attorneys for Equifax Information Services, LLC; Experian Information Solutions, Inc.; and National Consumer Telecom & Utilities Exchange, Inc.
Loren S. Young, Esq. LINCOLN, GUSTAFSON & CERCOS
Attorneys for TD Bank USA, N.A.
JOINT UNOPPOSED MOTION TO EXTEND DEADLINE FOR DEFENDANT COMENITY CAPITAL BANK N.A. TO RESPOND TO COMPLAINT
(FIRST REQUEST)
Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A) and Local Rule IA 6-1, Defendant Comenity Capital Bank N.A. (“Comenity”) and Plaintiff Marilea Ellis (“Plaintiff”), by and through their respective counsel, request that the Court grant their Joint Unopposed Motion to Extend the Time for Comenity to answer or otherwise respond to Plaintiff's Complaint. In support of this Motion, the parties stipulate as follows:
1. The Complaint was served on Comenity on March 14, 2023.
2. Comenity's current deadline to respond to the Complaint is April 4, 2023.
3. Comenity has diligently worked to find counsel and hired the law firm of Lipson Neilson P.C. on April 4, 2023. This extension is sought in good faith and will allow new counsel time to review the necessary documents and prepare a responsive pleading.
4. The parties met and conferred about the extension of time to respond to the Complaint and agreed that Comenity's deadline to respond to the Complaint may be extended to May 3, 2023.
5. There have been no prior extensions of Comenity's deadline to respond to the Complaint.
6. Accordingly, the parties respectfully and jointly request that the Court extend the deadline for Comenity to answer or otherwise respond to the Complaint to May 3, 2023.
ORDER
IT IS SO ORDERED.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 4th day of April, 2023, service of the foregoing JOINT UNOPPOSED MOTION TO EXTEND DEADLINE FOR DEFENDANT COMENITY CAPITAL BANK N.A. TO RESPOND TO COMPLAINT (FIRST REQUEST) was made upon each party in the case who is registered as an electronic case filing user pursuant to Fed. Rule Civ. P. 5(b)(3), and Local Rule 5-4, as follows: