Klein v. Nat'l Collegiate Student Loan Tr.

Full title: Richard Klein and Raymond Urias, individually and on behalf of all others…

Court: United States District Court, District of Nevada

Date published: Nov 21, 2022

2:22-cv-01392-GMN-BNW (D. Nev. Nov. 21, 2022)

Opinion

2:22-cv-01392-GMN-BNW

11-21-2022

Richard Klein and Raymond Urias, individually and on behalf of all others similarly situated, C Plaintiffs, v. National Collegiate Student Loan Trust AKA National Collegiate Master Student Loan Trust I; National Collegiate Student Loan Trust 2003-1; National Collegiate Student Loan Trust 2004-1; I National Collegiate Student Loan Trust 2004-2; National Collegiate Student Loan Trust 2005-1; National Collegiate Student Loan Trust 2005-2; National Collegiate Student Loan Trust 2005-3; National Collegiate Student Loan Trust 2006-1; National Collegiate Student Loan Trust 2006-2; National Collegiate Student Loan Trust 2006-3; National Collegiate Student Loan Trust 2006-4; 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;. Defendant.

FREEDOM LAW FIRM George Haines, Esq. Nevada Bar No. 9411 Gerardo Avalos, Esq. Nevada Bar No. 15171 MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN, PLLC Scott C. Harris* N.C. Bar No: 35328 Gary M. Klinger* *to motion for appearance pro hac vice Attorneys for Plaintiffs and the Proposed Class Attorneys for Plaintiff and on behalf of all others similarly situated WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez, Esq. Nevada Bar No. 13146 Darren T. Brenner Nevada Bar No. 8386, LOCKE LORD LLP Gregory T. Casamento (pro hac vice) R. James DeRose, III (pro hac vice) Brookfield Place J. Matthew Goodin (pro hac vice), Attorneys for Defendants

Gloria M. Navarro, District Judge

FREEDOM LAW FIRM George Haines, Esq. Nevada Bar No. 9411 Gerardo Avalos, Esq. Nevada Bar No. 15171 MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN, PLLC Scott C. Harris* N.C. Bar No: 35328 Gary M. Klinger* *to motion for appearance pro hac vice Attorneys for Plaintiffs and the Proposed Class Attorneys for Plaintiff and on behalf of all others similarly situated

WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez, Esq. Nevada Bar No. 13146 Darren T. Brenner Nevada Bar No. 8386, LOCKE LORD LLP Gregory T. Casamento (pro hac vice) R. James DeRose, III (pro hac vice) Brookfield Place J. Matthew Goodin (pro hac vice), Attorneys for Defendants

CLASS ACTION

STIPULATION AND ORDER FOR EXTENDING TIME FOR PLAINTIFFS TO RESPOND TO DEFENDANTS' MOTION TO DISMISS

Gloria M. Navarro, District Judge

Pursuant to Local Rules IA 6-1 and 7-1, Plaintiffs, Richard Klein and Raymond Urias (“Plaintiffs”) and National Collegiate Student Loan Trust et al (“Defendants”), by and through their Respective counsel of record, hereby stipulate, agree and respectfully request that the Court extend the deadline for the Plaintiffs to file their amended complaint to Defendant's Motion to Dismiss from November 30, 2022, to December 23, 2022. Counsel for Plaintiffs respectfully request time in light of their current schedule and the complexity of the matter. The parties have agreed that neither will seek to commence any discovery until, at the earliest, Defendants file their response to the Amended Complaint in a manner consistent with LR 26-1. The parties nevertheless reserve their rights to oppose the commencement of discovery, on grounds that it is premature or otherwise improper, including without limitation by seeking an order staying discovery pursuant to Fed. R. Civ P. 26. The parties also reserve their rights to request a lengthier discovery period than the one stated in LR 26-1.

ORDER

IT IS SO ORDERED.