Feld v. Pioneer Credit Recovery, Inc. et al

Filing 73

ORDER Granting 72 Stipulation for Extension of Time re 62 , 63 Motion for Summary Judgment. Responses due by 5/14/2022. Replies due by 5/21/2022. Signed by Judge Gloria M. Navarro on 4/7/2022. (Copies have been distributed pursuant to the NEF - JQC)

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George Haines, Esq.
Nevada Bar No. 9411
Gerardo Avalos, Esq.
Nevada Bar No. 15171
FREEDOM LAW FIRM, LLC
8985 South Eastern Ave., Suite 350
Las Vegas, NV 89123
Phone: [phone]
FAX: [phone]
Email: [e-mail]
Attorneys for Plaintiff Aaron Feld

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Aaron Feld,

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Case No.: 2:20-cv-01156-GMN-NJK
Plaintiff,

v.
Navient Solutions LLC and
Pioneer Credit Recovery, Inc.,

Stipulation and Order for an
extension of time for the Parties to
respond to their respective motions
for summary judgment

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Defendants.

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Aaron Feld (“Plaintiff”), Navient Solutions LLC, and Pioneer Credit
Recovery, Inc. (“Defendants”) (together as "the Parties") by counsel, hereby
submit this Stipulation and Order for an extension of time for the Parties to
respond to their respective motions for summary judgment. Both motions were
filed on January 12, 2022, this is the second request for an extension of this
deadline.

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_____________________
STIPULATION

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The extension is sought because, although the March 24, 2022 Settlement

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Conference with Judge Koppe was unsuccessful, the parties have since

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reengaged in settlement discussions. The parties hope to avoid the additional

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expense of briefing their respective motions, as without this added cost, may

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put the parties in a better position to reach a resolution.

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As such, the parties are requesting an extension of time to file their

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respective oppositions to the motions for summary judgment by 30 days from

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the current deadline of April 14, 2022 to May 14, 2022, with the reply deadline

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moved from April 21, 2022 to May 21, 2022.

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This Stipulation is brought in good faith and not for purposes of delay.

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The parties hereby request that the Court order that the Parties' oppositions to

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the pending motions for summary judgment shall be due on or before May 14,

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2022, with the reply due on or before May 21, 2022.

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Dated: April 7, 2022.

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FREEDOM LAW FIRM, LLC
/s/ Gerardo Avalos
.
Gerardo Avalos, Esq.
8985 S. Eastern Ave., Suite 350
Las Vegas, NV 89123
Counsel for Plaintiff

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SPENCER FANE LLP
/s/ Jessica Chong
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Jessica E. Chong, Esq.
300 S. Fourth St., Suite 950
Las Vegas, Nevada 89101
Counsel for Defendants

IT IS SO ORDERED.
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Dated this ____ day of April, 2022.

___________________________
Gloria M. Navarro, District Judge
UNITED STATES DISTRICT COURT

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_____________________
STIPULATION

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