Juan Moreno v. Credit One Bank, N.A.

Filing 13

ORDER Granting 9 Stipulation re 1 Complaint. Credit One Bank, N.A. answer due 2/1/2016. Signed by Chief Judge Gloria M. Navarro on 1/5/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-02135-GMN-PAL Document 9 Filed 12/23/15 Page 1 of 2

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Marek P. Bute
Nevada Bar No. 9989
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway
Suite 1100
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702.784.5252
Email: [e-mail]
Becca J. Wahlquist (pro hac vice pending)
SNELL & WILMER L.L.P.
350 South Grand Ave #2600
Los Angeles, CA 90071-3406
Tel: [phone]
Email: [e-mail]

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Attorneys for Defendant Credit One Bank, N.A.

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JUAN MORENO, individually and on behalf
of all
others similarly situated,,

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Plaintiff,

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CREDIT ONE BANK, N.A.,

STIPULATION AND ORDER TO
EXTEND TIME TO FILE ANSWER TO
CLASS ACTION COMPLAINT

vs.

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Case No. 2:15-CV-02135-GMN-PAL

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(FIRST REQUEST)

Defendant.

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Defendant Credit One Bank, N.A (“Credit One”), by and through its counsel at the law

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firm of Snell & Wilmer L.L.P., and Plaintiff Juan Moreno (“Plaintiff”), by and through his

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counsel at the law firms of Shook & Stone, Chtd. and Grant & Eisenhofer, P.A., hereby stipulate

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as follows:

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WHEREAS, Credit One was served with the Complaint and Summons in this action on
December 9, 2015, making its response due on December 31, 2015;
WHEREAS, Credit One needs time to investigate the Complaint’s allegations and confer
with Plaintiff’s counsel, and has only recently retained counsel to represent it in this action;

Case 2:15-cv-02135-GMN-PAL Document 9 Filed 12/23/15 Page 2 of 2

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WHEREAS, the Parties agree that this Stipulation is not made for the purposes of delay,

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and Plaintiff has agreed to Credit One’s request that it be given an additional thirty (30) days to

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respond to the Complaint, through February 1, 2016;

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THEREFORE, the Parties hereby agree that Credit One shall have until February 1, 2016

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to file a responsive pleading to Plaintiff’s Complaint, and that any such pleading filed by that date

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shall be deemed timely.

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By entering into this stipulation, Credit One does not waive any of its defenses or

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objections to the lawsuit, except that Credit One waives any objections to service of process of

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the Complaint.

10 Dated this 23rd day of December, 2015.

L.L.P.
LAW OFFICES

Snell & Wilmer

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Dated this 23rd day of December, 2015.

SNELL & WILMER L.L.P.

SHOOK & STONE, CHTD.

12 By: /s/ Marek P. Bute
By: _/s/Leonard H. Stone___________
Leonard H. Stone
Marek P. Bute
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Nevada Bar No. 5791
Nevada Bar No. 9989
710 South Fourth Street
3883 Howard Hughes Parkway, Suite 1100
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Las Vegas, Nevada 89101
Las Vegas, NV 89169
Tel: [phone]
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Becca J. Wahlquist (pro hac vice pending)
Adam J. Levitt (pro hac vice pending)
SNELL & WILMER L.L.P.
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Diane Zilka (pro hac vice pending)
350 South Grand Ave #2600
Kyle J. McGee (pro hac vice pending)
Los Angeles, CA 90071-3406
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GRANT & EISENHOFER P.A.
Tel: [phone]
30 North LaSalle Street, Suite 2350
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Chicago, Illinois 60602
Attorneys for Defendant
Tel: [phone]
Credit One Bank, N.A.
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Attorneys for Plaintiff
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ORDER
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IT IS SO ORDERED that Defendant Credit One Bank, N.A. shall have until February 1,
2016 to file a responsive pleading to Plaintiff’s Class Action Complaint in the above-captioned
matter.
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January
DATED this ____ day of __________________ 201___.
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________________________________________
UNITED STATES DISTRICT JUDGE

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