Opinion
2:22-cv-01348-GMN-NJK
11-03-2022
JESSICA SCHEDENECK, Plaintiff, v. PORTFOLIO RECOVERY ASSOCIATES, LLC Defendant.
Philip Lo (SBN: 12253) GORDON REES SCULLY MANSUKHANI, LLP Attorneys For Defendant Portfolio Recovery Associates, LLC
Philip Lo (SBN: 12253) GORDON REES SCULLY MANSUKHANI, LLP Attorneys For Defendant Portfolio Recovery Associates, LLC
MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT
(THIRD REQUEST)
Pursuant to Local Rule IA 6-1, Defendant Portfolio Recovery Associates, LLC (“PRA”) by and through its attorney, Philip Lo of Gordon Rees Scully Mansukhani, LLP hereby submits the following:
1. Pursuant to the second extension of time granted on October 20, 2022 (Dkt. 9), PRA's responsive pleading is due November 2, 2022.
2. As indicated in PRA's Stipulation to Extend Time to File Response to Complaint (Second Request) (Dkt. 8), PRA sought a second extension of time to conclude settlement discussions for a full resolution of this matter. (Dkt. 8, para. 7.)
3. The parties have reached a full resolution of the case. See Notice of Settlement dated October 31, 2022 (“NOS”) (Dkt. 10.)
4. The NOS states that Plaintiff anticipates filing dismissal documents within 60 days. (See Dkt. 10.)
5. Based on the foregoing and in light of the NOS, PRA requests an additional continuance of 45 days, through December 17, 2022, of the responsive pleading deadline.
6. Good cause exists, as this extension is sought to allow the parties to conclude resolution of the case pursuant to the NOS, and without incurring unnecessary fees and costs.
7. This motion is made in good faith and is not intended to inflict unnecessary delay.
8. Pursuant to this Court's local rules, a proposed Order has been attached hereto as Exhibit A.
IT IS SO ORDERED.