Opinion
2:22-cv-01392 GMN BNW
02-06-2023
Richard Klein, Raymond Urias and Sandra 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 Higher Education Assistance Agency d/b/a/ American Education Services; and Transworld Systems Inc., Defendants.
MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN Scott C. Harris George Haines Attorney for Plaintiffs Richard Klein, Raymond Urias and Sandra J. Gunter SESSIONS, ISRAEL & SHARTLE, LLP James K. Schultz Attorney for Defendant Transworld Systems Inc. BROWNSTEIN HYATT FARBER SCHRECK, LLP Patrick J. Reily Attorney for Defendant Pennsylvania High Education Assistance Agency LOCKE LORD LLP J. Matthew Goodin Attorney for Defendant National Collegiate Student Loan Trust
New Response Date: March 8, 2023
MILBERG COLEMAN BRYSON PHILLIPS GROSSMAN Scott C. Harris George Haines Attorney for Plaintiffs
Richard Klein, Raymond Urias and Sandra J. Gunter SESSIONS, ISRAEL & SHARTLE, LLP James K. Schultz Attorney for Defendant Transworld Systems Inc.
BROWNSTEIN HYATT FARBER SCHRECK, LLP Patrick J. Reily Attorney for Defendant Pennsylvania High Education Assistance Agency
LOCKE LORD LLP J. Matthew Goodin Attorney for Defendant National Collegiate Student Loan Trust
JOINT STIPULATED MOTION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANTS TO RESPOND TO FIRST AMENDED COMPLAINT SECOND REQUEST
It is hereby stipulated by Plaintiffs Richard Klein, Raymond Urias and Sandra J. Gunter (“Plaintiffs”) and Defendants Transworld Systems Inc. (“TSI”), National Collegiate Student Loan Trust (“NCSLT”) 2005-2, NCSLT 2006-3, NCSLT 20071, NCSLT 2007-2, and NCSLT 2007-3, and NCSLT 2007-4) (the “NCSLTs”), and Pennsylvania High Education Assistance Agency (“PHEAA”) (collectively, “Defendants”) through undersigned counsel, that Defendants may have an additional extension of time to respond to the First Amended Complaint (“FAC”) from February 6, 2023, through and until March 8, 2023. This Motion is made with respect to the following:
1. On August 26, 2022, Plaintiffs filed a Complaint against the NCSLTs.
2. On December 23, 2022, Plaintiffs filed a FAC, adding TSI and PHEAA as additional defendants herein.
3. On December 30, 2022, the NCSLTs filed their First Motion to Extend Deadline to Respond to the FAC. The NCSLTs were granted an extension until February 6, 2023 to respond. Joint Motion for Extension of Time (Second Request)
4. On January 17, 2023, TSI filed its First Request for Extension of Time to Respond to the FAC. TSI was granted an extension until to February 6, 2023 to respond.
5. On January 24, 2023, PHEAA filed its First Stipulation for Extension of Time to Respond to the FAC. PHEAA was granted an extension until February 6, 2023 to respond.
6. Additional time is needed through and including March 8, 2023 for defense counsel to evaluate the information necessary to appropriately respond to the FAC.
7. On January 27, 2023, counsel for TSI and Plaintiffs conferred regarding this proposed extension of time for all Defendants to respond to the FAC, and on January 28, 2023, counsel for plaintiff consented to the requested relief.
8. Granting this request for an extension of time for all Defendants to respond to the FAC will neither prejudice any party nor unreasonably delay the litigation.
IT IS SO STIPULATED.
Pursuant to the Parties' joint Motion, IT IS HEREBY ORDERED:
Defendant shall have an extension of time to and including March 8, 2023, for each Defendant to respond to the First Amended Complaint.