Opinion
2:21-cv-01948-JCM-BNW
01-21-2022
JAMES MOLINARO, Plaintiff, v. NATIONAL CONSUMER TELECOM & UTILITIES EXCHANGE, INC, Defendant.
Michael V. Infuso, Esq., Keith W. Barlow, Esq., Greene Infuso, LLP Attorneys for Defendant National Consumer Telecom &Utilities Exchange, Inc.
Michael V. Infuso, Esq., Keith W. Barlow, Esq., Greene Infuso, LLP Attorneys for Defendant National Consumer Telecom &Utilities Exchange, Inc.
AMENDED STIPULATION FOR EXTENSION OF TIME FOR NATIONAL CONSUMER TELECOM & UTILITIES EXCHANGE, INC. TO FILE RESPONSE TO COMPLAINT (SECOND REQUEST)
Defendant National Consumer Telecom & Utilities Exchange, Inc. (“Defendant” or “NCTUE”), by and through its counsel of record, the law firm Greene Infuso, LLP, and Plaintiff James Molinaro (“Plaintiff” or “Molinaro”), by and through his counsel of record, the law firm of Krieger Law Group, LLC, hereby stipulate and agree as follows:
WHEREAS, Plaintiff filed its Complaint on October 22, 202;
WHEREAS, Defendant NCTUE'S deadline to respond to Plaintiff's Complaint was December 20, 2021;
WHEREAS, due to settlement discussions between the parties that commenced on December 20, 2021, Plaintiff agreed that late that day that NCTUE may have an extension to respond to the Complaint to facilitate the parties' efforts to resolve this matter without the need for further litigation; 1
WHEREAS, the parties were unable to coordinate the preparation, review, execution and filing of a stipulation to extend NCTUE's deadline to respond to Plaintiff's Complaint until December 22, 2022 as a result of the parties' schedules and efforts directed towards resolving this matter;
WHEREAS, the parties continue to engage in settlement discussions and have agreed that NCTUE may have until January 27, 2022 in which to respond to Plaintiff's Complaint.
WHEREAS, there are no other deadlines that are affected by this stipulation that are presently known to the parties; and
WHEREAS, this stipulation is not entered into for any improper purpose or to delay;
THEREFORE, Plaintiff and NCTUE hereby stipulate and agree that NCTUE may have up through January 27, 2022 in which to respond to Plaintiff's Complaint.
ORDER
IT IS SO ORDERED. 2