Mallari v. National Consumer Telecom & Utilities Exchange, Inc. et al

Filing 11

ORDER Granting #9 Motion to Extend Time (First Request). AT&T Services, Inc. answer due 10/17/2022. Signed by Magistrate Judge Daniel J. Albregts on 9/16/2022. (Copies have been distributed pursuant to the NEF - TRW)

Case 2:22-cv-01365-CDS-DJA Document 11 Filed 09/16/22 Page 1 of 3

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WRIGHT, FINLAY & ZAK, LLP
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, DIRECTV, LLC

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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JONALETTE MALLARI,

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Case No.: 2:22-cv-01365-CDS-DJA

Plaintiff,
vs.

NATIONAL CONSUMER TELECOM &
UTILITIES EXCHANGE, INC., COX
COMMUNICATIONS LAS VEGAS, INC.,
AT&T SERVICES, INC. AND
BACKGROUNDCHECKS.COM LLC,

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

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Defendants.
Defendant, DIRECTV, LLC (incorrectly named AT&T Services, Inc.) (“Defendant”)
(collectively “Parties”), by and through its counsel of record, hereby moves as follows:

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On August 23, 2022, Plaintiff filed his Complaint [ECF No. 1]. Defendant was served with

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Plaintiff’s Complaint on August 25, 2022. The deadline for Defendant to respond to Plaintiff’s

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Complaint is September 15, 2022. The Parties have discussed extending the deadline for Defendant

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

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possible resolution of the matter. Defendant received consent for an extension via an email dated

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September 13, 2022, and sent a draft of a Joint Motion to Defendant on September 15, 2022, but

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Defendant did not receive a response from Plaintiff as to whether Defendant could include

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Plaintiff’s counsel’s signature to the joint motion.

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Therefore, Defendant moves to extend the deadline for Defendant to file its responsive
pleading to Plaintiff’s Complaint to October 17, 2022.
This is the first motion for an extension of time for Defendant to file its responsive

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Case 2:22-cv-01365-CDS-DJA Document 11 Filed 09/16/22 Page 2 of 3

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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.

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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 15th day of September, 2022.

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WRIGHT, FINLAY & ZAK, LLP

/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, DIRECTV, LLC

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IT IS SO ORDERED:

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___________________________________
UNITED J.STATES
MAGISTRATE JUDGE
DANIEL
ALBREGTS
UNITED STATES MAGISTRATE JUDGE

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DATED: _________________________
DATED: September 16, 2022

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Case 2:22-cv-01365-CDS-DJA Document 11 Filed 09/16/22 Page 3 of 3

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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 UNOPPOSED MOTION TO EXTEND TIME TO RESOND TO

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PLAINTIFF’S COMPLAINT (FIRST REQUEST) on the 15th day of September, 2022, to all

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parties on the CM/ECF service list.

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

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