Opinion
2:22-cv-02049-JCM-NJK
01-05-2023
TYLER K. JONES, an individual Plaintiff, v. BANK OF AMERICA, N.A., a national banking association; EQUIFAX INFORMATION SERVICES, LLC, a foreign limited-liability company; EXPERIAN INFORMATION SOLUTIONS, INC., a foreign corporation; TRANS UNION LLC, a foreign limited-liability company; Defendants.
WRIGHT, FINLAY & ZAK, LLP Jory C. Garabedian Darren T. Brenner, Esq. Attorneys for Bank of America, N.A.
WRIGHT, FINLAY & ZAK, LLP
Jory C. Garabedian
Darren T. Brenner, Esq.
Attorneys for Bank of America, N.A.
UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S COMPLAINT
(FIRST REQUEST)
Defendant Bank of America N.A. (“BANA”) by and through its undersigned counsel of record, hereby submits the following Unopposed Motion to Extend Time to Respond to Plaintiff's Complaint (First Request):
On December 9, 2022, Plaintiff filed his Complaint [ECF No. 1]. The Summons and Complaint were purportedly served on BANA on December 15, 2022, which makes the initial deadline to respond to the Complaint January 5, 2023.
BANA's counsel is still investigating the allegations raised in Plaintiff's Complaint. Further, Plaintiff and BANA have discussed extending the deadline 30-days to February 6, 2023, in order to explore early resolution opportunities. On January 4, 2023, BANA received approval of the 30-day extension request from Plaintiff's counsel.
Based upon the foregoing, BANA respectfully requests that the Court extend the deadline for BANA to file its response to Plaintiff's Complaint to February 6, 2023. This is the first request for extension of time for BANA to respond to Plaintiff's Complaint. The extension is requested in good faith and is not for purposes of delay or prejudice to any other party.
IT IS SO ORDERED: