Filed: May 15, 2019
Latest Update: May 15, 2019
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO FIRST AMENDED COMPLAINT (First Request) GEORGE FOLEY, JR. , Magistrate Judge . Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenberg
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO FIRST AMENDED COMPLAINT (First Request) GEORGE FOLEY, JR. , Magistrate Judge . Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenberg ..
More
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO FIRST AMENDED COMPLAINT
(First Request)
GEORGE FOLEY, JR., Magistrate Judge.
Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenberg Traurig, LLP, hereby stipulate and request that the Court extend the time by which Defendant must respond to the First Amended Class Action Complaint by thirty (30) days up to, and including, June 21, 2019. This Stipulation is made and based upon the following:
1. Plaintiffs filed their First Amended Class Action Complaint on May 8, 2019, in which they allege Defendant breached contractual duties as custodian of Plaintiffs' Individual Retirement Accounts. [ECF No. 46]. Plaintiffs seek certification to represent a class of similarly situated individuals across the country. Id.
2. Defendant was served with the First Amended Class Action Complaint via PACER on May 8, 2019, and Defendant's response is currently due May 22, 2019. Id.
3. Counsel for Defendant has requested additional time to evaluate Plaintiffs' allegations and prepare a response, taking into account the exercise of due diligence. Counsel for Plaintiffs has agreed to this request.
4. In light of the foregoing, the parties agree that Defendant shall have up to, and including, June 21, 2019, to respond to the First Amended Class Action Complaint.
5. This is the first request for an extension of time in this regard. This Stipulation is entered into in good faith and not for purposes of delay.
DATED this 14th day of May, 2019. DATED this 14th day of May, 2019.
/s/Jason Hicks /s/ Christopher Gray
Mark F. Ferrario, Esq. Martin L. Welsh, Esq.
Jason K. Hicks, Esq. LAW OFFICE OF HAYES & WELSH
GREENBERG TRAURIG, LLP
Christopher J. Gray, Esq.
Robert H. Bernstein, Esq. LAW OFFICE OF CHRISTOPHER J. GRAY
Michael J. Slocum, Esq.
GREENBERG TRAURIG, LLP Joshua B. Kons, Esq.
Attorneys for Defendants LAW OFFICES OF JOSHUA B. KONS
Attorneys for Plaintiffs
IT IS SO ORDERED.
