Baker v. Specialized Loan Servicing, LLC et al

Western District of Texas, txwd-5:2019-cv-01298

Second MOTION for Extension of Time to File Answer re [1] Complaint by Experian Information Solutions, Inc.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION Paul E. Baker,)) Plaintiff,)) v.) CIVIL ACTION NO.) Specialized Loan Servicing, LLC, et al.,) 5:19-cv-1298-OLG) Defendants.)))) DEFENDANT EXPERIAN INFORMATION SOLUTIONS, INC.'S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND CERTIFICATE OF CONFERENCE COMES NOW Defendant Experian Information Solutions, Inc. ("Experian") and files this Unopposed Second Motion for Extension of Time to Respond to the Complaint, and would respectfully show the Court as follows: 1. The current deadline for Experian to answer or otherwise respond to Plaintiff's Complaint (ECF No. 1) is January 13, 2020. 2. Experian desires additional time to review Plaintiff's Complaint, investigate its allegations, and prepare an appropriate response. 3. There has been one prior request for extension. 4. Counsel for Plaintiff and Experian conferred regarding Experian's deadline to respond to Plaintiff's Complaint, and Plaintiff is not opposed to a one-month (30 day) extension, which would make Experian's new deadline to answer or otherwise respond to Plaintiff's complaint February 12, 2020. 5. This extension is sought in good faith and not for the purpose of delay. Neither party will be prejudiced by this extension WHEREFORE, Experian respectfully requests that this Court grant its Unopposed Motion for Extension of Time to Respond to Plaintiff's Complaint. Dated: January 3, 2020 /s/ Michael A. Erdmann Michael A. Erdmann Texas Bar No. 24055453 JONES DAY 2727 North Harwood Street Dallas, Texas 75201 Tel.: (214) 969-4505 Fax: (214) 969-5100 merdmann@jonesday.com Counsel for Defendant, Experian Information Solutions, Inc. CERTIFICATE OF CONFERENCE I hereby certify that Counsel for Experian conferred with counsel for Plaintiff regarding the requested relief by email on January 2, 2020, and Plaintiff is unopposed to the requested extension. /s/ Michael A. Erdmann Michael A. Erdmann CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of January, 2020, I caused the foregoing to be electronically filed with the clerk of court for the U.S. District Court for the Western District of Texas, by using the CM/ECF system, which will send a notice of electronic filing to all counsel of record. /s/ Michael Allan Erdmann Michael Allan Erdmann Attorney for Defendant Experian Information Solutions, Inc.