STIPULATION AND PROPOSED ORDER TO GRANT PLAINTIFF LEAVE TO AMEND AND TO CONTINUE EDUCATIONAL FINANCIAL SOLUTIONS, LLC DBA CAMPUS DEBT SOLUTIONS'S DEADLINE TO RESPOND TO THE COMPLAINT

JON S. TIGAR, District Judge.

COMES NOW THE PARTIES TO THE ABOVE-REFERENCED ACTION AND RECITE AND STIPULATE AS FOLLOWS:

1. WHEREAS, Plaintiff initiated this lawsuit on March 4, 2016;

2. WHEREAS, Plaintiff filed a First Amended Complaint by way of stipulation on September 23, 2016.

3. WHEREAS, Plaintiff has expressed a desire to amend the Complaint.

4. WHEREAS, to avoid unnecessary litigation expense, and without waiving any defenses and/or opposition to any of the claims and/or class allegations, the Parties agree that Plaintiff may file a Second Amended Complaint on or before March 24, 2017 and Defendant Educational Financial Solutions, LLC dba Campus Debt Solutions may have through June 19, 2017 to answer, move, or otherwise respond to the Second Amended Complaint.

NOW THEREFORE THE PARTIES STIPULATE:

1. Plaintiff may file a Second Amended Complaint on or before March 24, 2017.

2. Educational Financial Solutions, LLC dba Campus Debt Solutions may have through June 19, 2017 to answer, move, or otherwise respond to the Second Amended Complaint.

ORDER

Pursuant to the Parties' stipulation,

1. Plaintiff may have through March 24, 2017 to file a Second Amended Complaint

2. Educational Financial Solutions, LLC dba Campus Debt Solutions may have through June 19, 2017 to answer, move, or otherwise respond to the Second Amended Complaint.

IT IS SO ORDERED.