Baker v. Specialized Loan Servicing, LLC et al

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

Unopposed MOTION for Extension of Time to File Answer re [1] Complaint and Certificate of Conference 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 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 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 December 13, 2019. 2. Experian desires additional time to review Plaintiff's Complaint, investigate its allegations, and prepare an appropriate response. 3. There have been no prior requests for extensions. 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 January 13, 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: December 11, 2019 /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 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 December 6, 2019, and Plaintiff is unopposed to the requested extension. /s/ Michael A. Erdmann Michael A. Erdmann CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11th day of December, 2019, I caused a copy of the forgoing to be served upon the following: BY FIRST CLASS MAIL: William Maurice Clanton Law Office of Bill Clanton, P.C. 926 Chulie Dr. San Antonio, TX 78216 (210) 226-0800 Fax: (210) 338-8660 Email: Attorney for Plaintiff Paul E. Baker /s/ Michael A. Erdmann Michael A. Erdmann