Opinion
2:22-cv-01392-GMN-BNW
01-03-2023
Richard Klein and Raymond Urias, 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 Higher Education Assistance Agency d/b/a American Education Services; and Transworld Systems, Inc. Defendants.
WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez, Esq. Attorneys for Defendants, 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, and National Collegiate Student Loan Trust 2007-4 FREEDOM LAW FIRM George Haines, Esq. Attorneys for Plaintiffs, Richard Klein and Raymond Urias
WRIGHT, FINLAY & ZAK, LLP Ramir M. Hernandez, Esq. Attorneys for Defendants, 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, and National Collegiate Student Loan Trust 2007-4
FREEDOM LAW FIRM George Haines, Esq. Attorneys for Plaintiffs, Richard Klein and Raymond Urias
JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFFS' FIRST AMENDED COMPLAINT (FIRST REQUEST)
Plaintiffs, Richard Klein and Raymond Urias (“Plaintiffs”), and Defendants, Attorneys for 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, and National Collegiate Student Loan Trust 20074 (“Defendants”) (collectively “Parties”), by and through their counsel of record, hereby stipulate and agree as follows:
On August 26, 2022, Plaintiffs filed their Complaint [ECF No. 1]. Defendants were served with Plaintiffs' Complaint on September 19, 2022. The deadline for Defendants to respond to Plaintiffs' Complaint was October 11, 2022. After a joint motion of the parties, the Court extended the deadline for Defendants to respond to Plaintiffs' Complaint to November 9, 2022 [ECF No. 8]. Thereafter, Defendants filed a Motion to Dismiss on November 9, 2022 [ECF No. 12]. The parties then stipulated to extend the time for Plaintiffs to Respond to the Motion to Dismiss to December 23, 2022 [ECF No. 18], and the Court entered an Order to that effect [ECF No. 19]. On December 23, 2022, Plaintiffs filed their First Amended Complaint [ECF No. 20].
The Parties have discussed extending the deadline for Defendants to respond to Plaintiffs' First Amended Complaint to allow for better investigation of new allegations.
WHEREAS, the Parties hereby stipulate and agree to extend the deadline for Defendants to file their responsive pleading to Plaintiffs' First Amended Complaint to February 6, 2023. The parties further agree that the stipulation regarding discovery as set forth in ECF No. 19 remain in effect and are unaffected by this stipulation. 2
This is the first motion for an extension of time for Defendants to file their responsive pleading to the First Amended 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. 3