Opinion
2:22-cv-02041-GMN-NJK
02-14-2023
Patrick J. Reilly, Esq. Ashley N. Schobert, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for Maximus Education LLC dba Aidvantage George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Marlaina Smith
Patrick J. Reilly, Esq. Ashley N. Schobert, Esq. BROWNSTEIN HYATT FARBER SCHRECK, LLP Attorneys for Maximus Education LLC dba Aidvantage
George Haines, Esq. Gerardo Avalos, Esq. FREEDOM LAW FIRM Attorneys for Marlaina Smith
ORDER TO EXTEND DEADLINE TO RESPOND TO COMPLAINT (SECOND 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. Pursuant to a Stipulation and Order dated February 2, 2023 (ECF No. 48), the current deadline for Aidvantage to respond to Plaintiff's Complaint is February 15, 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, March 1, 2023, in which to answer or otherwise plead in response to the 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 continue to confer with opposing counsel regarding possible settlement of this action.
7. This is the second and will be the last request by Aidvantage to respond to the Complaint.
8. 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.
9. This is the second request for extension of time requested by the parties with respect to responding to the Complaint.
DATED this 13th day of February, 2023.
ORDER
IT IS SO ORDERED.