Holstein v. Transunion, LLC et al

Filing 9

ORDER Granting #5 Motion to Extend Time - Transunion, LLC answer due 2/7/2022. Signed by Magistrate Judge Cam Ferenbach on 1/6/2022. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:21-cv-02199-JAD-VCF Document 9 Filed 01/06/22 Page 1 of 4

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JENNIFER BERGH
Nevada Bar No. 14480
QUILLING SELANDER LOWNDS
WINSLETT & MOSER, P.C.
2001 Bryan Street, Suite 1800
Dallas, TX 75201
Telephone: [phone]
Facsimile: [phone]
[e-mail]
COUNSEL FOR TRANS UNION LLC
**Designated Attorney for Personal Service**
Kurt Bonds, Esq.
Nevada Bar No.: 6228
6605 Grand Montecito Parkway, Suite 200
Las Vegas, Nevada 89149
IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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DANIEL HOLSTEIN,
Plaintiff,
v.
TRANSUNION, LLC, EXPERIAN
INFORMATION SOLUTIONS, INC. and
AVANT, LLC,

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Defendants.

Case No. 2:21-cv-02199-JAD-VCF
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 Daniel Holstein (“Plaintiff”) and Defendant Trans Union LLC (“Trans Union”),
by and through their respective counsel, file this Joint Motion Extending Defendant Trans Union’s
Time to File an Answer or Otherwise Respond to Plaintiff’s Complaint.
1.

On December 14, 2021, Plaintiff filed his Complaint. The current deadline for

Trans Union to answer or otherwise respond to Plaintiff’s Complaint is January 6, 2022.
2.

On December 30, 2021, counsel for Trans Union communicated with Plaintiff’s

counsel via email regarding an extension within which to file a response to the Complaint, and
Plaintiff’s counsel agreed to the extension.
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5340782.1

Case 2:21-cv-02199-JAD-VCF Document 9 Filed 01/06/22 Page 2 of 4

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3.

The parties will actively discuss a potential early resolution of this case, and the

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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.

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4.

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 in

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good faith and not for the purposes of delay.

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5.

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

otherwise respond to Plaintiff’s Complaint up to and including February 7, 2022. This is the first
motion for extension of time for Trans Union to respond to Plaintiff’s Complaint.
Dated this 6th day of January 2022.

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QUILLING SELANDER LOWNDS
WINSLETT & MOSER, P.C.

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/s/ Jennifer Bergh
JENNIFER BERGH
Nevada Bar No. 14480
[e-mail]
2001 Bryan Street, Suite 1800
Dallas, TX 75201
[phone]
[phone] Fax
Counsel for Trans Union LLC

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CONTEMPORARY LEGAL SOLUTIONS PLLC

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/s/ Robert M. Tzall
ROBERT M. TZALL
Nevada Bar No. 013412
[e-mail]
2551 North Green Valley Parkway, Building C, Suite
303
Henderson, NV 89014
[phone]
Counsel for Plaintiff

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Case 2:21-cv-02199-JAD-VCF Document 9 Filed 01/06/22 Page 3 of 4

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ORDER
The Joint Motion for Extension of Time for Trans Union LLC to file an answer or
otherwise respond to Plaintiff’s Complaint is so ORDERED AND ADJUDGED.
Dated this 6th day of January 2022.

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UNITED STATES MAGISTRATE JUDGE

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Case 2:21-cv-02199-JAD-VCF Document 9 Filed 01/06/22 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on this the 6th of January 2022, I filed JOINT MOTION AND

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ORDER EXTENDING DEFENDANT TRANS UNION LLC’S TIME TO FILE AN

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ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT with the Clerk of

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the Court using the CM/ECF system, which will send notification of such filing to the following

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counsel:

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Robert M. Tzall
[e-mail]
Contemporary Legal Solutions PLLC
2551 N. Green Valley Parkway, Building C
Suite 303
Henderson, NV 89014
[phone]
Counsel for Plaintiff

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/s/ Jennifer Bergh
JENNIFER BERGH

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