Opinion
2:23-cv-01201
08-29-2023
Jodie Lasky, Plaintiff, v. Equifax Information Services, LLC; Experian Information Solutions, Inc.; The Bank of Missouri, N.A.; Wells Fargo Bank, N.A.; Capital One Bank, N.A.; and First Premier Bank, LLC, Defendants.
Freedom Law Firm, LLC George Haines, Esq. Gerardo Avalos, Esq. Attorneys for Plaintiff
Freedom Law Firm, LLC George Haines, Esq. Gerardo Avalos, Esq. Attorneys for Plaintiff
UNOPPOSED MOTION FOR EXTENSION OF TIME FOR THE BANK OF MISSOURI, N.A. TO ANSWER OR OTHERWISE PLEAD
FIRST REQUEST
Plaintiff Jodie Lasky, hereby files this Unopposed Motion for Extension of Time for the Bank of Missouri, N.A. to Answer or Otherwise Plead, and in support states:
The Bank of Missouri, N.A.'s (“The Bank of Missouri”) responsive pleading was due on August 25, 2023.
Plaintiff and The Bank of Missouri are actively engaged in case resolution negotiations.
Plaintiff does not oppose an extension of The Bank of Missouri's time to answer the Complaint so that the parties may devote energies to resolving this matter.
Plaintiff files this Motion consistent with its agreement with The Bank of Missouri and further files this motion respectfully requesting the Court for an extension of time for The Bank of Missouri to file its responsive pleading for 14 days to Friday, September 8, 2023.
Good cause exists for this extension because it will allow The Bank of Missouri and its counsel to complete their investigation of the Plaintiff's claim and possible defenses and prepare responsive pleading. It is further expected that counsel for Plaintiff and The Bank of Missouri will continue to discuss whether this matter may be resolved without further intervention from the Court in the interim.
This is the first request for an extension of this deadline and the request is made after the deadline has expired due to excusable neglect. The parties previously agreed to an informal extension when they began negotiations for early resolution but the parties failed to submit a request to the Court.
For the forgoing reasons, Plaintiff requests that the Court issue an order extending the date to September 8, 2023 on which The Bank of Missouri must answer Plaintiff's complaint or otherwise plead.
IT IS SO ORDERED: