Unopposed MOTION for Extension of Time to File Response/Reply as to 24 MOTION to… — Greathouse Capitalplus (Dkt. 29)

Summary

An Unopposed Motion for Extension of Time to File Response to Defendants' Motion to Dismiss, Doc. 29, filed March 2, 2022 in Greathouse v. Capital Plus Financial, LLC and Crossroads Systems, Inc., No. 4:21-cv-01243-BRW, in the U.S. District Court for the Eastern District of Arkansas. Plaintiff Eric Greathouse states that the defendants filed a Motion to Dismiss and Brief in Support on February 25, 2022, that the opposition is currently due on or before March 11, 2022, and that the deadline to amend as a matter of course is currently March 18, 2022. The motion asks that the response, by opposition or amended complaint, be extended through March 28, 2022. It states that counsel for the defendants have no objection.

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       Case 4:21-cv-01243-BRW            Document 29        Filed 03/02/22      Page 1 of 2




                       IN THE UNITED STATES DISTRICT COURT
                      FOR THE EASTERN DISTRICT OF ARKANSAS
                                 CENTRAL DIVISION


  ERIC GREATHOUSE, individually and on
  behalf of all others similarly situated,

                                                      Case No. 4:21-cv-01243-BRW
                 Plaintiff,

  v.                                                  UNOPPOSED MOTION FOR
                                                      EXTENSION OF TIME TO FILE
  CAPITAL PLUS FINANCIAL, LLC and                     RESPONSE TO DEFENDANTS’
  CROSSROADS SYSTEMS, INC.,                           MOTION TO DISMISS

                 Defendants.



       Plaintiff Eric Greathouse, individually and on behalf of all others similarly situated, for his

Unopposed Motion for Extension of Time To File a Response to Defendants’ Motion to Dismiss,

states as follows:

       1.      Defendants Capital Plus Financial, LLC and Crossroads Systems, Inc. filed a

Motion to Dismiss and Brief in Support (Doc. Nos. 24 & 25) on February 25, 2022 (the “Motion”).

       2.      Plaintiff’s opposition to the Motion is currently due on or before March 11, 2022.

       3.      Plaintiff’s deadline to amend as a matter of course pursuant to Fed. R. Civ. P.

15(a)(1)(B) is currently March 18, 2022.

       4.      Plaintiff requests that his response to the Motion either by way of an opposition or

an amended complaint be extended for an additional period of time through March 28, 2022, that

the Court does not adjudicate the Motion pending the filing of Plaintiff’s response, and that an

Order be entered reflecting the same.

       5.      Counsel for Defendants have no objection to Plaintiff’s requested extension.

       6.      This extension is sought in good faith and not for the purpose of undue delay.
       Case 4:21-cv-01243-BRW          Document 29         Filed 03/02/22    Page 2 of 2




       WHEREFORE, Plaintiff, Eric Greathouse, individually and on behalf of all others

similarly situated, prays that this Court grant his Unopposed Motion for Extension and that he be

awarded any additional relief as may be just and proper.

Dated: March 2, 2022                        Respectfully submitted,

                                            FRIDAY, ELDREGE & CLARK, LLP
                                            Marshall S. Ney, AR 91108
                                            Katherine C. Campbell, AR 2013241
                                            3350 S. Pinnacle Hills Parkway, Suite 301
                                            Rogers, AR 72758
                                            479-695-6049 Office
                                            501-244-5389 Facsimile
                                            mney@fridayfirm.com
                                            kcampbell@fridayfirm.com

                                            AND

                                           BAILEY & GLASSER LLP
                                           Lawrence J. Lederer (pro hac vice)
                                           Michael L. Murphy (pro hac vice)
                                           Bart D. Cohen (pro hac vice)
                                           1055 Thomas Jefferson Street NW, Suite 540
                                           Washington, DC 20007
                                           T.:     202.463-2101
                                           F.:     202.463-2103
                                           llederer@baileyglasser.com
                                           mmurphy@baileyglasser.com
                                           bcohen@baileyglasser.com

                                            NOLAN HELLER KAUFFMAN LLP
                                            Justin A. Heller (pro hac vice)
                                            Matthew M. Zapala (pro hac vice)
                                            80 State Street, 11th Floor
                                            Albany, NY 12207
                                            T.:     518.449.3300
                                            jheller@nhkllp.com
                                            mzapala@nhkllp.com




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