Opinion
2:23-CV-00073-JCM-VCF
02-08-2023
LYNEECE JAMES, Plaintiff, v. CHEX SYSTEMS, INC.; and BANK OF AMERICA, N.A., Defendants.
FREEDOM LAW FIRM George Haines, Esq. (NV Bar #9411) Gerardo Avalos, Esq. (NV Bar #15171) Attorneys for Plaintiff Lyneece James SNELL & WILMER L.L.P. John S. Delikanakis, Esq. (NV Bar #5928) Skylar Arakawa-Pamphilon (NV Bar #15864) Attorneys for Defendants Bank of America, N.A. and Chex Systems, Inc.
FREEDOM LAW FIRM
George Haines, Esq. (NV Bar #9411)
Gerardo Avalos, Esq. (NV Bar #15171)
Attorneys for Plaintiff Lyneece James
SNELL & WILMER L.L.P.
John S. Delikanakis, Esq. (NV Bar #5928)
Skylar Arakawa-Pamphilon (NV Bar #15864)
Attorneys for Defendants Bank of America, N.A. and Chex Systems, Inc.
STIPULATION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT [ECF NO. 1] (FIRST REQUEST)
CAM FERENBACH UNITED STATES MAGISTRATE JUDGE
Pursuant to LR IA 6-1 and LR IA 6-2, Defendants Chex Systems, Inc. (“CHEX”) and Bank of America, N.A. (“BANA,” and collectively with CHEX, “Defendants”), by and through their attorneys of record, and Plaintiff Lyneece James (“Plaintiff”), by and through Plaintiff's counsel of record, submit this Stipulation and Proposed Order, based on the following:
1. Plaintiff filed the Complaint on January 12, 2023 [ECF No. 1].
2. Both Defendants were served with Plaintiff's Complaint, and their responsive pleadings are due on February 7, 2023.
3. Defendants have requested that the deadline for Defendants to file an answer to Plaintiff's Complaint be extended by twenty (20) days up to and including February 27, 2023.
4. This request for an extension is made in good faith and is not intended to cause any delay or prejudice to any party. The reason for this request is to provide Defendants sufficient time to evaluate and respond to the allegations set forth in the Complaint and to allow time for the Parties to engage in settlement negotiations.
5. Counsel for Defendants reached out to counsel for Plaintiff on February 6, 2023 requesting the extension. Plaintiff's counsel has responded and consents to this request.
IT IS HEREBY STIPULATED AND AGREED by and between the Parties that the deadline for Defendants to file respond to Plaintiff's Complaint shall be Monday, February 27, 2023.
IT IS SO STIPULATED.
IT IS SO ORDERED.