Opinion
2:20-cv-01156-GMN-NJK
04-07-2022
Aaron Feld, Plaintiff, v. Navient Solutions LLC and Pioneer Credit Recovery, Inc., Defendants.
George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM, LLC Attorneys for Plaintiff Aaron Feld SPENCER FANE LLP Jessica E. Chong, Esq. Counsel for Defendants
George Haines, Esq.
Gerardo Avalos, Esq.
FREEDOM LAW FIRM, LLC
Attorneys for Plaintiff Aaron Feld
SPENCER FANE LLP
Jessica E. Chong, Esq.
Counsel for Defendants
STIPULATION AND ORDER FOR AN EXTENSION OF TIME FOR THE PARTIES TO RESPOND TO THEIR RESPECTIVE MOTIONS FOR SUMMARY JUDGMENT
GLORIA M. NAVARRO, DISTRICT JUDGE UNITED STATES DISTRICT COURT
Aaron Feld (“Plaintiff”), Navient Solutions LLC, and Pioneer Credit Recovery, Inc. (“Defendants”) (together as "the Parties") by counsel, hereby submit this Stipulation and Order for an extension of time for the Parties to respond to their respective motions for summary judgment. Both motions were filed on January 12, 2022, this is the second request for an extension of this deadline.
The extension is sought because, although the March 24, 2022 Settlement Conference with Judge Koppe was unsuccessful, the parties have since reengaged in settlement discussions. The parties hope to avoid the additional expense of briefing their respective motions, as without this added cost, may put the parties in a better position to reach a resolution.
As such, the parties are requesting an extension of time to file their respective oppositions to the motions for summary judgment by 30 days from the current deadline of April 14, 2022 to May 14, 2022, with the reply deadline moved from April 21, 2022 to May 21, 2022.
This Stipulation is brought in good faith and not for purposes of delay. The parties hereby request that the Court order that the Parties' oppositions to the pending motions for summary judgment shall be due on or before May 14, 2022, with the reply due on or before May 21, 2022.
Dated: April 7, 2022.
FREEDOM LAW FIRM, LLC
Gerardo Avalos, Esq.
Counsel for Plaintiff
SPENCER FANE LLP
Jessica E. Chong, Esq.
Counsel for Defendants
IT IS SO ORDERED.