ANDREW P. GORDON, District Judge.
Plaintiff FRANCINE EDWARDS, individually and on behalf of all others similarly situated ("Plaintiff"), by and through her counsel of record, and Defendants CONN'S, INC. and CONN APPLIANCES, INC. ("Defendants"), by and through their counsel of record, hereby submit this agreement and stipulation to extend the time for Plaintiff to respond to [28] Defendants' 12(b)(6) Motion to Dismiss for Failure to State a Claim on Which Relief Can Be Granted, [29] Motion to Dismiss Non-Nevada Putative Class Members' Claims for Lack of Personal Jurisdiction, and [30] Motion to Strike Failsafe Class Allegations and Impertinent and Immaterial Matter [Doc. No.'s. 28, 29, and 30] ("the Motions") pursuant to LR IA 6-1.
Plaintiff's current deadline to respond to all three motions is next Monday, April 1, 2019. Plaintiff and Defendants stipulate and agree Plaintiff shall have an additional two weeks until April 15, 2019 to file her responses to the three Motions. Two days ago, Defendants also filed a Motion to Stay Discovery which requires Plaintiff to draft and file a response to this additional fourth motion filed by Defendants.
Plaintiff filed her Original Class Action Complaint on October 17, 2018. After reviewing Defendants' three Motions, and having recent conversations with Defendants' counsel, Plaintiff now seeks to amend her complaint to add specific facts and more detailed allegations against Defendants and their agents. However, Plaintiff cannot spend time amending the complaint while also drafting and responding to the three pending Motions to dismiss and fourth Motion to Stay Discovery.
This is Plaintiff's second request for an extension of time to respond to these Motions. It's not intended to cause any delay or prejudice to any party, but rather to allow sufficient time for Plaintiff to draft and file three responses to Defendants' pending Motions to dismiss and a fourth response to Defendants' recent Motion to Stay Discovery.