Opinion
2:22-cv-01392-GMN-BNW
01-25-2023
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 George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Plaintiffs and the Class
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
George Haines, Esq.
Gerardo Avalos, Esq.
FREEDOM LAW FIRM
Attorneys for Plaintiffs and the Class
STIPULATION TO AND PROPOSED ORDER EXTEND DEADLINE TO RESPOND TO PLAINTIFFS' FIRST AMENDED COMPLAINT (FIRST REQUEST)
BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE
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 stipulate and agree as follows:
1. On December 23, 2022, Plaintiffs filed their First Amended Complaint (the 25135473. “Amended Complaint”). ECF No. 20.
2. On December 29, 2022, Plaintiff served the Summons and Amended Complaint on AES. ECF No. 24.
3. The deadline to respond to the Amended Complaint was originally set for January 19, 2023.
4. AES promptly pursued counsel and just recently retained the undersigned counsel for this action.
5. AES's inability to clear conflicts and retain the undersigned counsel until recently constitutes excusable neglect for AES not filing its response to the Amended Complaint by the original deadline.
6. Plaintiffs have agreed to grant an extension for AES to respond to the Amended Complaint.
7. The Parties have agreed that AES shall have until February 6, 2023 to answer or otherwise plead in response to the Amended Complaint.
8. This is the first requested extension by AES.
9. No previous extensions have been sought by AES or granted for AES, and no further requests are expected.
10. This stipulation is brought in good faith by all parties and not for purposes of delay.
ORDER
IT IS SO ORDERED