STIPULATION AND [PROPOSED] ORDER TO EXTEND DEFENDANT NAVIENT SOLUTIONS, LLC'S TIME TO RESPOND TO COMPLAINT

PEGGY A. LEEN, District Judge.

This second Stipulation to Extend Time to Respond to Complaint is made by and between Plaintiff Ruth A. Kane ("Plaintiff") and Defendant Navient Solutions, LLC ("NSL") through their respective counsel, in light of the following facts:

RECITALS

A. Plaintiff filed the Complaint ("Complaint") against NSL on or about March 7, 2018.

B. NSL was served with the Complaint on or about March 8, 2018.

C. On March 26, 2018, this Court extended NSL's response deadline until April 26, 2018.

D. The parties have diligently conferred regarding this matter but require additional time to research the claims at issue.

E. The Parties therefore have mutually agreed to extend NSL's time to respond to the Complaint an additional two weeks until May 10, 2018.

F. The parties agree that the requested extension will permit the parties to continue to research the claims at issue and discuss a potential resolution of this matter.

G. There is good cause to grant this stipulation because the Parties require additional time to investigate Plaintiff's claims and to consider a potential resolution of this matter.

H. Pursuant to Local Rule IA 6-2 and Local Rule 7.1, Plaintiff and NSL respectfully request that the Court extend NSL time to respond to Plaintiff's Complaint through May 10, 2018.

STIPULATION

NOW, THEREFORE, Plaintiff and NSL hereby stipulate and agree that NSL has up to and including May 10, 2018, to file a response to Plaintiff's Complaint.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED