Faughn et al v. JPMorgan Chase Bank, NA

Filing 51

Consent MOTION for extension of time to re-file Complaint filed by Rick D. Holtsclaw on behalf of All Plaintiffs. Suggestions in opposition/response due by 4/24/2015 unless otherwise directed by the court. (Holtsclaw, Rick)

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION
MARK FAUGHN, et al.,
Plaintiffs,
vs.
JPMORGAN CHASE BANK, N.A.,
Defendant.

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Case No. 14-CV-00245-BCW

UNOPPOSED MOTION FOR EXTENSION OF TIME TO RE-FILE COMPLAINT
COME NOW Plaintiffs, by and through counsel of record, and move the Court for an
extension of time to re-file their Complaint in accordance with the Court’s Order of March 30,
2015. Plaintiffs request an additional 30 days to prepare their Complaint, making the deadline
to re-file the Complaint May 13, 2015. Plaintiffs’ counsel has conferred with Defendant’s
counsel, and Defendant consents to the 30-day extension. The extension is requested so that
Plaintiffs’ counsel has sufficient opportunity to ensure that there are no impermissible
references to the documents the Court has struck from the record.
WHEREFORE, for the foregoing reasons, Plaintiffs respectfully request that the Court
grant this motion and permit Plaintiffs to re-file their Complaint on or before May 13, 2015.

Respectfully submitted,
/s/ Rick D. Holtsclaw
Rick D. Holtsclaw, MO #32866
HOLTSCLAW FIRM
2029 Wyandotte, Suite 100
Kansas City, Missouri 64108
Telephone: [phone]
Facsimile: [phone]
[e-mail]
ATTORNEY FOR PLAINTIFFS
CERTIFICATE OF SERVICE
I certify that on this 7th day of April, 2015, I filed the above and foregoing electronically
with CM/ECF, which will automatically transmit a copy of this document to Defendant’s counsel
of record.
/s/ Rick D. Holtsclaw
Attorney for Plaintiffs

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