Piskorowski v. The Bank of Missouri et al

Filing 27

ORDER Granting #26 Motion to Extend Time (Second Request) for Defendant Bank of Missouri to Respond to Complain re #1 Complaint. The Bank of Missouri answer due 3/19/2025. Signed by Magistrate Judge Daniel J. Albregts on 3/6/2025. (Copies have been distributed pursuant to the NEF - ALZ)

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Noah Kane, Esq.
Consumer Attorneys PLLC
68-29 Main Street
Flushing, NY 11367
518-375-3963
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff Valerie Piskorowski

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James J. Lee, Esq.
Nevada Bar No. 001909
Legal Offices of James J. Lee
2620 Regatta Dr. #102
Las Vegas, NV 89102
702-664-6545
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendant The Bank of
Missouri

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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VALERIE PISKOROWSKI,

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Plaintiff,
v.

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EXPERIAN INFORMATION
SOLUTIONS, INC., EQUIFAX
INFORMATION SERVICES, LLC,
TRANS UNION LLC, AND THE
BANK OF MISSOURI,

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Defendants.

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Case No.: 2:25-cv-00122-JCM-DJA
JOINT MOTION FOR EXTENSION OF
TIME FOR DEFENDANT THE BANK OF
MISSOURI TO RESPOND TO
COMPLAINT
SECOND REQUEST

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Defendant The Bank of Missouri (“TBOM”) has requested a second extension of

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time to answer, move or otherwise respond to the Complaint of Plaintiff Valerie

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Piskorowski (“Plaintiff” and together with TBOM, the “Parties”), to which Plaintiff has

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no opposition. Accordingly, by this joint motion, IT IS HEREBY STIPULATED AND

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AGREED to by and among counsel, that Defendant The Bank of Missouri’s time to

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-1JOINT MOTION

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answer, move or otherwise respond to the Complaint in this action is extended from

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March 5, 2025 through and including March 19, 2025.

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Good cause exists for the request. TBOM is still in the process of compiling,

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reviewing, and evaluating its business records and other files related to the allegations

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and claims in the Complaint. TBOM has requested this second extension so it has

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sufficient time to complete those tasks before responding to the Complaint, and Plaintiff

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approves. The Parties are also engaged in discussions regarding the action, including

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issues related to the arbitrability of certain claims. This second extension will provide the

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Parties with additional time to continue their discussions regarding the matter and the

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potential for a resolution of the claims early in the case.

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This joint motion is filed in good faith and not for the purposes of delay. This is
the second request for an extension of this deadline.

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TBOM has not waived any objection to the venue or jurisdiction of the Court over

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the person of TBOM, or any other challenge to Plaintiff’s complaint or other pleadings

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filed in this case.

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Respectfully submitted, this 5th day of March, 2025.

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Consumer Attorneys PLLC

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/s/ Noah Kane
Noah Kane, Esq.
68-29 Main Street
Flushing, NY 11367
Attorneys for Plaintiff Valerie Piskorowski

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Legal Offices of James J. Lee

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/s/ James J. Lee
James J. Lee, Esq.
2620 Regatta Dr. #102
Las Vegas, NV 89102
Attorneys for Defendant The Bank of
Missouri

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-2JOINT MOTION

ORDER

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IT
ORDERED
that the parties' joint motion (ECF No. 26) is GRANTED. The Bank of Missouri
ITISISSOSO
ORDERED:
shall have until March 19, 2025 to respond to the complaint.

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____________________________________

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

DATED:____________________________

DATED: 3/6/2025

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-3JOINT MOTION