Santos v. Discover Financial Services LLC et al

Filing 16

ORDER granting 11 Motion to Extend Time to Respond to 1 Complaint. Discover Financial Services LLC answer due 1/25/2021. Signed by Magistrate Judge Cam Ferenbach on 1/7/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:20-cv-02053-JCM-VCF Document 16 Filed 01/07/21 Page 1 of 3

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J Christopher Jorgensen
Nevada Bar No. 5382
Matthew R. Tsai
Nevada Bar No. 14290
LEWIS ROCA ROTHGERBER CHRISTIE LLP
3993 Howard Hughes Pkwy, Suite 600
Las Vegas, NV 89169-5996
Tel: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant Discover
Financial Services, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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NATHALIE SANTOS, an individual,

3993 Howard Hughes Pkwy, Suite 600
Las Vegas, NV 89169-5996

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Case No.: 2:20-cv-02053-JCM-VCF

Plaintiff,
vs.
DISCOVER FINANCIAL SERVICES
LLC, a foreign limited-liability company;
EQUIFAX INFORMATION SERVICES,
LLC, a foreign limited-liability company;
EXPERIAN INFORMATION
SOLUTIONS, INC., a foreign corporation,

DISCOVER FINANCIAL
SERVICES, LLC’S UNOPPOSED
MOTION TO EXTEND
DEADLINE TO RESPOND TO
COMPLAINT
(FIRST REQUEST)

Defendant.

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Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Discover Financial Services,

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LLC (“Discover”), through its attorneys, respectfully requests that the Court extend the

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deadline in which Discover has to answer or otherwise plead to Plaintiff’s Complaint, by

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fourteen (14) days, through and until January 25, 2021. In support of its Motion, Discover

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states as follows:

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1.

Plaintiff’s Complaint was filed on November 6, 2020. [ECF No. 1].

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2.

After executing a waiver of service, Discover's deadline to respond to the

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Plaintiff’s Complaint is currently January 11, 2021.
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Discover now respectfully requests that the Court extend Discover's deadline

to respond to the Complaint by fourteen (14) days through and including January 25, 2021.
113250020.1

Case 2:20-cv-02053-JCM-VCF Document 16 Filed 01/07/21 Page 2 of 3

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4.

This is Discover's first request for an extension; this request is brought in

good faith and not made to unnecessarily delay discovery or the proceedings in this matter.
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No party will be prejudiced by the requested extension nor, respectfully, will

the extension unduly burden the Court.
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Counsel for Discover sought concurrence to this motion from counsel for

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Plaintiff and concurrence was obtained to extend the deadline to January 25, 2021. Counsel

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for Plaintiff has agreed to extend the response deadline by fourteen (14) days.
WHEREFORE defendant Discover respectfully requests that the Court grant its

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Unopposed Motion to Extend Deadline to Respond to Complaint (“Motion”), extending its

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deadline to answer or otherwise plead to Plaintiff’s Complaint through and until January 25,

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3993 Howard Hughes Pkwy, Suite 600
Las Vegas, NV 89169-5996

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2021, and award such other relief the Court deems just and proper.

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DATED this 7th day of January, 2021.

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LEWIS ROCA ROTHGERBER CHRISTIE LLP

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/s/ J Christopher Jorgensen
J Christopher Jorgensen
Nevada Bar No. 5382
Matthew R. Tsai
Nevada Bar No. 14290
3993 Howard Hughes Pkwy, Suite 600
Las Vegas, NV 89169-599

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Attorneys for Defendant Discover Financial
Services, LLC

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ORDER

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IT IS SO ORDERED.

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United States Magistrate Judge

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Dated:

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113250020.1

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1-7-2021

Case 2:20-cv-02053-JCM-VCF Document 11 Filed 01/07/21 Page 3 of 3
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CERTIFICATE OF SERVICE

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I hereby certify that on this 7th day of January, 2021, I caused a true and accurate

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copy of the foregoing document entitled Discover Financial Services, LLC’s Unopposed

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Motion to Extend Deadline to Respond to Complaint to be filed with the Clerk of the

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Court via the CM/ECF system, which will send an electronic copy to all interested parties.

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/s/ Annette Jaramillo
An employee of Lewis Roca
Rothgerber Christie LLP

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3993 Howard Hughes Pkwy, Suite 600
Las Vegas, NV 89169-5996

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113250020.1

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