Opinion
2:22-cv-02041-GMN-NJK
01-04-2023
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 COMPLAINT
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 (First Request):
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 makes the initial deadline to respond to the Complaint January 3, 2023.
BANA's counsel is still investigating the allegations raised in Plaintiff's Complaint. Further, Plaintiff and BANA have discussed extending the deadline 30-days to February 2, 2023, in order to explore early resolution opportunities. On January 3, 2023, BANA received approval of the 30-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 Complaint to February 2, 2023. This is the first request for extension of time for BANA to respond to Plaintiff's Complaint. The extension is requested in good faith and is not for purposes of delay or prejudice to any other party.
IT IS SO ORDERED.