Opinion
2:22-cv-01392-GMN-BNW
04-17-2023
RICHARD KLEIN, RAYMOND URIAS, and SARA J. GUNTER, individually and on behalf of all others similarly situated, Plaintiffs, v. NATIONAL COLLEGIATE STUDENT LOAN TRUST 2005-3; NATIONAL COLLEGIATE STUDENT LOAN TRUST 2006-3; NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-1; NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-2; NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-3; NATIONAL COLLEGIATE STUDENT LOAN TRUST 2007-4; PENNSYLVANIA HIGH EDUCATION ASSISTANCE AGENCY d/b/a AMERICAN EDUCATION SERVICES; and TRANSWORLD SYSTEMS, INC., Defendants.
Patrick J. Reilly, Esq. Monique S. Jammer, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for American Education Services, LLC Scott C. Harris, Esq. George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Plaintiffs and the Class
Patrick J. Reilly, Esq.
Monique S. Jammer, Esq.
BROWNSTEIN HYATT FARBER SCHRECK, LLP
Attorneys for American Education Services, LLC
Scott C. Harris, Esq.
George Haines, Esq.
Gerardo Avalos, Esq.
FREEDOM LAW FIRM
Attorneys for Plaintiffs and the Class
STIPULATION AND ORDER EXTENDING DEADLINE TO FILE REPLY MEMORANDUM IN SUPPORT OF AES' MOTION TO DISMISS
(FIRST REQUEST)
STIPULATION
Plaintiffs Richard Klein, Raymond Urias, and Sara J. Gunter (“Plaintiffs”), and Defendant American Education Services, LLC (“AES”), by and through their undersigned counsel, hereby jointly stipulate, agree, and move as follows:
1. On March 13, 2023, AES filed and served their Motion to Dismiss Amended Complaint (the “Motion”). ECF No. 42.
2. On April 10, 2023, Plaintiffs served their opposition to the Motion. ECF No. 52.
3. Pursuant to LR 7-2, AES's reply memorandum is due to be filed on April 17, 2023.
4. Counsel for AES traveled to Great Lakes, Illinois during the week of April 10, 2023, to attend his son's graduation from U.S. Navy Recruit Training Command at Great Lakes Naval Base.
5. Additional time is therefore needed to prepare and file the reply memorandum in support of the Motion.
6. The Parties have agreed that AES shall have up to and including April 24, 2023, to file its reply memorandum in support of its Motion.
7. This is the first requested extension by AES for this filing, which will neither prejudice any party nor unreasonably delay the litigation.
IT IS SO STIPULATED.
ORDER
Pursuant to the foregoing Joint Stipulated Motion, and with good cause and excusable neglect appearing, IT IS HEREBY ORDERED as follows:
AES shall have up to and including April 24, 2023 to file its to file its reply memorandum in support of its Motion to Dismiss Amended Complaint (ECF No. 42).
IT IS SO ORDERED.