Willis v. Transunion, LLC et al

Filing 13

ORDER granting #10 Motion to Extend Time Re: #1 Complaint, Berlin-Wheeler, Inc. answer due 5/23/2022. Signed by Magistrate Judge Daniel J. Albregts on 5/10/2022. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:22-cv-00609-RFB-DJA Document 10 Filed 05/09/22 Page 1 of 3
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05/10/22

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WRIGHT, FINLAY & ZAK, LLP
Christina V. Miller, Esq.
Nevada Bar No. 12448
Ramir M. Hernandez, Esq.
Nevada Bar No. 13146
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
[phone]; Fax: [phone]
[e-mail]
Attorneys for Defendant, Berlin-Wheeler, Inc.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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Case No.: 2:22-cv-00609-RFB-DJA

ELIZABETH WILLIS,

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Plaintiff,

JOINT MOTION TO EXTEND
DEADLINE TO RESPOND TO
PLAINTIFF’S COMPLAINT (FIRST
REQUEST)

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vs.
TRANSUNION, LLC, EQUIFAX
INFORMATION SERVICES, LLC, BERLINWHEELER, INC.,

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Defendants.

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Plaintiff, Elizabeth Willis (“Plaintiff”), and Defendant, Berlin-Wheeler, Inc. (“Defendant”)

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(collectively “Parties”), by and through their counsel of record, hereby stipulate and agree as

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follows:

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On April 11, 2022, Plaintiff filed his Complaint [ECF No. 1]. Defendant was served with

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Plaintiff’s Complaint on April 18, 2022. The deadline for Defendant to respond to Plaintiff’s

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Complaint is May 9, 2022. The Parties have discussed extending the deadline for Defendant to

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respond to Plaintiff’s Complaint to allow for better investigation of the allegations and discuss

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possible resolution of the matter.

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WHEREAS, the Parties hereby stipulate and agree to extend the deadline for Defendant to
file their responsive pleading to Plaintiff’s Complaint to May 23, 2022.

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This is the first motion for an extension of time for Defendant to file their responsive

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pleading. The extension is requested in good faith and is not for purposes of delay or prejudice to

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any other party.
As part of this motion, Defendant agrees to participate in any Rule 26(f) conference that
occurs during the pendency of this extension.
DATED this 9th day of May, 2022.

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WRIGHT, FINLAY & ZAK, LLP

CONTEMPORARY LEGAL SOLUTIONS

/s/ Ramir M. Hernandez
Ramir M. Hernandez, Esq.
Nevada Bar No. 13146
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
Attorneys for Defendant, Berlin-Wheeler, Inc.

/s/ Robert M. Tzall
Robert M. Tzall, Esq.
Nevada Bar No. 13412
2551 North Green Valley Pkwy
Building C, Suite 303
Henderson, NV 89014
Attorneys for Plaintiff, Elizabeth Willis

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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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May 10, 2022
_________________________

Case 2:22-cv-00609-RFB-DJA Document 10 Filed 05/09/22 Page 3 of 3
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05/10/22

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that I am an employee of WRIGHT, FINLAY & ZAK, LLP and

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that I served the foregoing JOINT MOTION TO EXTEND TIME TO RESOND TO

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PLAINTIFF’S COMPLAINT (FIRST REQUEST) on the 9th day of May, 2022, to all parties

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on the CM/ECF service list.

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/s/ Jason Craig
An Employee of WRIGHT, FINLAY & ZAK, LLP

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