Opinion
2:23-cv-00075-APG-DJA
02-15-2023
CRYSTAL POTTER, individually and on behalf of all others similarly situated, Plaintiff, v. SAMUEL BOND LLC, BEARDEN INSURANCE GROUP INC., and KIMENKER AGENCY INC., Defendants. v.
BALLARD SPAHR LLP BY JOEL E. TASCA MADELEINE COLES COUNSEL FOR DEFENDANTS ANTHONY I. PARONICH BRODERICK & PARONICH, PC TIMOTHY J. SOSTRIN KEOGH LAW, LTD JEFFREY A. COGAN JEFFREY A. COGAN ESQ LTD ATTORNEYS FOR PLAINTIFF
BALLARD SPAHR LLP BY JOEL E. TASCA MADELEINE COLES COUNSEL FOR DEFENDANTS
ANTHONY I. PARONICH BRODERICK & PARONICH, PC TIMOTHY J. SOSTRIN KEOGH LAW, LTD JEFFREY A. COGAN JEFFREY A. COGAN ESQ LTD ATTORNEYS FOR PLAINTIFF
DEFENDANTS' UNOPPOSED JOINT MOTION FOR AN EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S CLASS ACTION COMPLAINT
(First Request)
Defendants Samuel Bond LLC (“Bond”), Bearden Insurance Group Inc. (“Bearden”), and Kimenker Agency, Inc. (“Kimenker”) (collectively “Defendants”), pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Local Rule IA 6-1, respectfully move for an alignment and 30-day extension, from February 16, 2023, of their deadlines to respond to the Class Action Complaint filed by Plaintiff Crystal Potter (“Plaintiff”). In support of this motion, Defendants state as follows:
1. Plaintiff filed her Class Action Complaint on January 15, 2023. ECF 1. Plaintiff served Kimenker with process on January 26, 2023 (ECF 12), Bond on January 28, 2023 (ECF 11), and Bearden on January 30, 2023 (ECF 13). Thus, Kimenker's current deadline to respond to the Class Action Complaint is February 16, 2023, Bond's is February 18, 2023, and Bearden's is February 20, 2023. See Fed.R.Civ.P. 12(a)(1)(A)(i).
2. In light of the factual and legal complexity of Plaintiff's allegations, Defendants' counsel requires additional time to confer with Defendants, investigate the facts alleged, and prepare an appropriate response to the Class Action Complaint.
3. Accordingly, Defendants seek an alignment and a 30-day extension of their deadlines-starting from February 16, 2023 (the earliest current deadline)-to respond to Plaintiffs' Class Action Complaint.
4. This is Defendants' first requested extension of time in this case. This motion is not made for delay or any other improper purpose but only to promote orderly resolution of issues in this case.
5. Plaintiff's counsel does not oppose Defendants' requested extension.
WHEREFORE, Defendants respectfully request that the Court enter an order aligning and extending the time by which Defendants must file their response to Plaintiff's Class Action Complaint for 30 days from February 16, 2023.
ORDER
IT IS SO ORDERED: