Opinion
2:22-cv-01365-CDS-DJA
10-18-2022
JONALETTE MALLARI, Plaintiff, v. NATIONAL CONSUMER TELECOM & UTILITIES EXCHANGE, INC., COX COMMUNICATIONS LAS VEGAS, INC., AT&T SERVICES, INC. AND BACKGROUNDCHECKS.COM LLC, Defendants.
WRIGHT, FINLAY & ZAK, LLP KIND LAW Ramir M. Hernandez, Esq. Attorney for Defendant, DIRECTV, LLC KIND LAW Michael Kind, Esq. FREEDOM LAW FIRM Gerardo Avalos, Esq. Plaintiff, Jonalette Mallari
WRIGHT, FINLAY & ZAK, LLP KIND LAW
Ramir M. Hernandez, Esq.
Attorney for Defendant, DIRECTV, LLC
KIND LAW
Michael Kind, Esq.
FREEDOM LAW FIRM
Gerardo Avalos, Esq.
Plaintiff, Jonalette Mallari
JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT (SECOND REQUEST)
Plaintiff, Jonalette Mallari (“Plaintiff”), and Defendant, DIRECTV, LLC (“Defendant”) (collectively “Parties”), by and through their counsel of record, hereby moves as follows:
On August 23, 2022, Plaintiff filed his Complaint [ECF No. 1]. Defendant was served with Plaintiff's Complaint on August 25, 2022. The original deadline for Defendant to respond to Plaintiff's Complaint was September 15, 2022. On September 16, 2022, the Court granted Defendant's Unopposed Motion to Extend Deadline to Respond to Plaintiff's Complaint, which was set October 17, 2022, as the new deadline [ECF No. 11]. The Parties have discussed extending the deadline for Defendant to respond to Plaintiff's Complaint to allow for better investigation of the allegations and discuss possible resolution of the matter.
WHEREAS, the Parties hereby stipulate and agree to extend the deadline for Defendant to file their responsive pleading to Plaintiff's Complaint to November 7, 2022.
This is the second motion for an extension of time for Defendant to file their responsive pleading. The parties are actively discussing settlement. In the event the parties cannot resolve the case, it is anticipated that they will stipulate to remove the case to arbitration. The extension is requested in good faith and is not for purposes of delay or prejudice to any other party.
As part of this motion, Defendant agrees to participate in any Rule 26(f) conference that occurs during the pendency of this extension.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I am an employee of WRIGHT, FINLAY & ZAK, LLP and that I served the foregoing JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S COMPLAINT (SECOND REQUEST) on the 17th day of October, 2022, to all parties on the CM/ECF service list.
Lisa Cox
An Employee of WRIGHT, FINLAY & ZAK, LLP