Opinion
2:23-cv-00028-RFB-VCF
02-06-2023
LISA ESPITIA, Plaintiff, v. EXPERIAN INFORMATION SOLUTIONS, INC.; CONN APPLIANCES, INC. and SYNCHRONY BANK, Defendants.
WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez Ramir M. Hernandez, Esq. Nevada Bar No. 13146 Attorneys for Defendant, Conn Appliances, Inc. FREEDOM LAW FIRM Gerardo Avalos Gerardo Avalos, Esq. Nevada Bar No. 15171 Attorneys for Plaintiff, Lisa Espitia
WRIGHT, FINLAY & ZAK, LLP
Ramir M. Hernandez
Ramir M. Hernandez, Esq.
Nevada Bar No. 13146
Attorneys for Defendant, Conn Appliances, Inc.
FREEDOM LAW FIRM
Gerardo Avalos
Gerardo Avalos, Esq.
Nevada Bar No. 15171
Attorneys for Plaintiff, Lisa Espitia
JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT (FIRST REQUEST)
Plaintiff, Lisa Espitia (“Plaintiff”), and Defendant, Conn Appliances, Inc. (“Defendant”) (collectively “Parties”), by and through their counsel of record, hereby stipulate and agree as follows:
On January 5, 2023, Plaintiff filed his Complaint [ECF No. 1]. Defendant was served with Plaintiff's Complaint on January 9, 2023. The deadline for Defendant to respond to Plaintiff's Complaint is January 30, 2023. The Parties have discussed extending the deadline for Defendant 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 Defendant to file its responsive pleading to Plaintiff's Complaint to March 1, 2023.
This is the first motion for an extension of time for Defendant to file its responsive pleading. 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, Defendant agrees to participate in any Rule 26(f) conference that occurs during the pendency of this extension.
IT IS SO ORDERED: