Opinion
2:22-cv-01013-CDS-NJK
08-31-2022
George Haines, Freedom Law Firm Attorneys for Plaintiffs George Haines, Gerardo Avalos, Scott C. Hanis, Gary M. Klinger, Attorneys for Plaintiffs Anthony W. Austin Kendall M. Lovell Pro hac forthcoming Attorneys for Defendant
George Haines, Freedom Law Firm Attorneys for Plaintiffs
George Haines, Gerardo Avalos, Scott C. Hanis, Gary M. Klinger, Attorneys for Plaintiffs
Anthony W. Austin Kendall M. Lovell Pro hac forthcoming Attorneys for Defendant
STIPULATION EXTENDING PLAINTIFFS' TIME TO FILE RESPONSIVE PLEADING TO DEFENDANT'S MOTION TO COMPEL ARBITRATION (First Request)
Plaintiff Christina Fennell, individually and on behalf of all other similarly situated, (“Plaintiffs”), and Defendant Navient Solutions, LLC (“Defendant”) (collectively referred to as the "Parties") hereby submit the following this Stipulation Extending Plaintiffs' Time to File Responsive Pleading to Defendant's Motion to Compel Arbitration. This is the first request for an extension of this deadline. The Plaintiffs' counsel are dealing with deadlines in other matters and require additional time to review the facts and case law presented in Defendant's Motion to Compel Arbitration. (ECF No. 20). This extension is requested in good faith and is not for purposes of delay or prejudice to any party.
Procedural History
On June 28, 2022, Plaintiffs filed a complaint in the United States District Court, District of Nevada; Christina Fennell, individually and on behalf of all others similarly situated, v. Naient Solutions, LLC, No. 2:22-cv-01013-CDS-NJK-RFB-EJY. (ECF No. 1). Defendant filed a Motion to Compel Arbitration on August 18, 2022. (ECF No. 20). Plaintiffs' response to the Defendant's Motion to Compel Arbitration is due on September 1, 2022.
THEREFORE, the Parties hereby stipulate and agree to extend the deadline for Plaintiffs' to file an amended complaint or other responsive pleading to September 22, 2022.
IT IS SO STIPULATED.
Dated: August 29, 2022 Dated: August 29, 2022
FREEDOM LAW FIRM
FENNEMORE CRAIG, P.C.
MILBERG COLEMAN BRYSON PHILLIPS PLLC
MCGUIRE WOODS LP
IT IS SO ORDERED.