Opinion
2:22-cv-01392-GMN-BNW
04-24-2023
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. Nevada Bar No. 6103 Monique S. Jammer, Esq. Nevada Bar No. 15420 BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for American Education Services, LLC
Patrick J. Reilly, Esq.
Nevada Bar No. 6103
Monique S. Jammer, Esq.
Nevada Bar No. 15420
BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for American Education Services, LLC
STIPULATION AND ORDER EXTENDING DEADLINE TO FILE REPLY MEMORANDUM IN SUPPORT OF AES' MOTION TO DISMISS
(Second 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. Accordingly, this Court granted a previous stipulation to extend to April 24, 2023 the deadline for AES to prepare and file the reply memorandum in support of the Motion.
6. Additional time is needed for AES to review and approve the draft reply memorandum in support of the Motion before it is filed.
7. The Parties have agreed that AES shall have up to and including May 1, 2023, to file its reply memorandum in support of its Motion.
8. This is the second 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 May 1, 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.