Opinion
2:22-cv-02041-GMN-NJK
02-02-2023
MARLAINA SMITH, Plaintiff, v. TRANS UNION, LLC; EQUIFAX INFORMATION SERVICES, LLC; EXPERIAN INFORMATION SOLUTIONS, INC.; JPMORGAN CHASE BANK, N.A.; CITIBANK, N.A.; BANK OF AMERICA, N.A.; MAXIMUS EDUCATION LLC DBA AIDVANTAGE; AND NAVIENT SOLUTIONS, LLC, Defendants.
Patrick J. Reilly, Esq. George Haines, Esq. Ashley N. Schobert, Esq. Gerardo Avalos, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP FREEDOM LAW FIRM
Patrick J. Reilly, Esq.
George Haines, Esq.
Ashley N. Schobert, Esq.
Gerardo Avalos, Esq.
BROWNSTEIN HYATT FARBER SCHRECK, LLP
FREEDOM LAW FIRM
ORDER TO EXTEND DEADLINE TO RESPOND TO COMPLAINT
(First Request)
STIPULATION
Defendant Maximum Education LLC dba Aidvantage (“Aidvantage”), by and through its counsel of record, Patrick J. Reilly, Esq., and Ashley N. Schobert, Esq., of the law firm of Brownstein Hyatt Farber Schreck, LLP, and Plaintiff Marlaina Smith (“Plaintiff”) by and through her counsel of record, George Haines, Esq., and Gerardo Avalos, Esq., of Freedom Law Firm, LLC, hereby stipulate and agree as follows:
1. On January 10, 2023, Plaintiff filed her First Amended Complaint for Damages Under the FCRA, 15 U.S.C. §1681 (the “Complaint”). ECF No. 35.
2. On or about January 11, 2023, Plaintiff served the Summons and Complaint on Aidvantage.
3. The current deadline for Aidvantage to respond to Plaintiff's Complaint is February 1, 2023.
4. Plaintiff has agreed to grant an extension for Aidvantage to answer or otherwise plead in response to the Complaint.
5. Aidvantage shall have up to, and including, February 15, 2023, in which to answer or otherwise plead in response to Plaintiff's Complaint.
6. Aidvantage seeks additional time to respond to the Complaint so that it may gather additional relevant documentation and information, conduct an initial investigation of the Complaint's allegations in order to formulate a response to the Complaint, and confer with opposing counsel regarding possible settlement of this action.
7. This stipulation is brought in good faith by all parties and not for purposes of delay. This extension will not result in any undue delay in the administration of this case.
8. This is the first request for extension of time requested by the parties with respect to responding to the Complaint.
ORDER
IT IS SO ORDERED.