Root v. American Express National Bank et al

Filing 19

ORDER granting 17 Motion to Extend Time to Answer 1 Complaint; Trans Union LLC answer due 3/8/2021. Signed by Magistrate Judge Nancy J. Koppe on 2/17/2021. (Copies have been distributed pursuant to the NEF - DRS)

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JENNIFER BERGH
Nevada Bar No. 14480
QUILLING SELANDER LOWNDS
WINSLETT & MOSER, P.C.
2001 Bryan Street, Suite 1800
Dallas, Texas 75201
Telephone: [phone]
Facsimile: [phone]
[e-mail]
COUNSEL FOR TRANS UNION LLC
**Designated Attorney for Personal Service**
Trevor Waite, Esq.
Nevada Bar No.: 13779
6605 Grand Montecito Parkway, Suite 200
Las Vegas, Nevada 89149

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA
JAMES ROOT,

Case No. 2:20-cv-02267-RFB-NJK
Plaintiff,

v.
AMERICAN EXPRESS NATIONAL BANK,
EXPERIAN INFORMATION SOLUTIONS,
INC., TRANS UNION LLC,
Defendants.

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JOINT MOTION AND ORDER
EXTENDING DEFENDANT TRANS
UNION LLC’S TIME TO FILE AN
ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S
COMPLAINT
(FIRST REQUEST)

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Plaintiff James Root (“Plaintiff”) and Defendant Trans Union LLC (“Trans Union”), by

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and through their respective counsel, file this Joint Motion Extending Defendant Trans Union’s

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Time to File an Answer or Otherwise Respond to Plaintiff’s Complaint.
1.

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On December 15, 2020, Plaintiff filed his Complaint. The current deadline for

Trans Union to answer or otherwise respond to Plaintiff’s Complaint is February 16, 2021.
2.

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On February 15, 2021, counsel for Trans Union communicated with Plaintiff’s

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counsel via email regarding an extension within which to file a response to the Complaint, and

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Plaintiff’s counsel agreed to the extension.
3.

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The parties are actively discussing a potential early resolution of this case, and the

parties believe an extension of this nature may save waste of the parties’ time and expense. The
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additional time will allow Plaintiff and Trans Union time to fully explore such early settlement

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discussions.
4.

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Moreover, Trans Union’s counsel will need additional time to review the

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documents and respond to the allegations in Plaintiff’s Complaint. This Joint Motion is made

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in good faith and not for the purposes of delay.
5.

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Plaintiff has agreed to extend the deadline in which Trans Union has to answer or

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otherwise respond to Plaintiff’s Complaint up to and including March 8, 2021. This is the first

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motion for extension of time for Trans Union to respond to Plaintiff’s Complaint.

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Dated this 16th day of February 2021.
QUILLING SELANDER LOWNDS
WINSLETT & MOSER, P.C.

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/s/ Jennifer Bergh
Jennifer Bergh
Nevada Bar No. 14480
2001 Bryan Street, Suite 1800
Dallas, Texas 75201
Telephone: [phone]
Facsimile: [phone]
[e-mail]
COUNSEL FOR TRANS UNION LLC

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LAW OFFICE OF KEVIN L. HERNANDEZ

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/s/ Kevin L. Hernandez
Kevin L. Hernandez
Nevada Bar No. 12594
8872 S. Eastern Ave., Suite 270
Las Vegas, NV 89123
Telephone: [phone]
Facsimile: [phone]
[e-mail]
COUNSEL FOR PLAINTIFF

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Case 2:20-cv-02267-RFB-NJK Document 17 Filed 02/16/21 Page 3 of 4
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ORDER

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The Joint Motion for Extension of Time for Trans Union LLC to file an answer or

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otherwise respond to Plaintiff’s Complaint is so ORDERED AND ADJUDGED.

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Dated:this ______ day of ______________________ 2021.
Dated February 17, 2021

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UNITED STATES MAGISTRATE JUDGE

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