Opinion
2:22-cv-02041-GMN-NJK
02-03-2023
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.; US. DEPARTMENT OF EDUCATION; and NAVIENT SOLUTIONS, LLC, Defendants.
WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. Nevada Bar No. 8386 Jory C. Garabedian, Esq. Nevada Bar No. 10352 Attorneys for Bank of America, N.A.
WRIGHT, FINLAY & ZAK, LLP Darren T. Brenner, Esq. Nevada Bar No. 8386 Jory C. Garabedian, Esq. Nevada Bar No. 10352 Attorneys for Bank of America, N.A.
UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT (FIRST REQUEST AS TO FIRST AMENDED COMPLAINT; SECOND REQUEST TO EXTEND TIME IN GENERAL)
Defendant Bank of America N.A. (“BANA”) by and through its undersigned counsel of record, hereby submits the following Unopposed Motion to Extend Time to Respond to Plaintiff's Complaint:
On December 8, 2022, Plaintiff filed her Complaint. (ECF No. 1). The Summons and Complaint were purportedly served on BANA on December 12, 2022, which made the initial deadline to respond to the Complaint January 3, 2023.
On January 4, 2023, this Court extended the time to respond to the Complaint to February 2, 2023. (ECF No. 26).
On January 10, 2023, Plaintiff filed her First Amended Complaint. (ECF No. 35).
BANA continues to investigate the allegations raised in Plaintiff's Complaint and First Amended Complaint and is considering a settlement offer/demand received from Plaintiff. Further, Plaintiff and BANA have discussed extending the deadline an additional 21-days to February 23, 2023, in order to continue to explore early resolution opportunities. On February 2, 2023, BANA received approval of the 21-day extension request from Plaintiff's counsel.
Based upon the foregoing, BANA respectfully requests that the Court extend the deadline for BANA to file its response to Plaintiff's First Amended Complaint to February 23, 2023. This is the first request for extension of time for BANA to respond Plaintiff's First Amended Complaint, and second request for extension of time to respond to Plaintiff's allegations/claims in general. The extension is requested in good faith and is not for purposes of delay or prejudice to any other party.
IT IS SO ORDERED: