Unopposed MOTION for Extension of Time to File Response/Reply as to 45 Brief in… — Greathouse Capitalplus (Dkt. 47)

Summary

An Unopposed Motion for Extension of Time to File Response to Defendants' Motion to Dismiss, Doc. 47, filed May 4, 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. Plaintiffs Eric Greathouse, Ernesto Covarrubias, Tiffany Sumrall, and Barbara Myles state that the defendants filed a Motion to Dismiss and Brief in Support on April 29, 2022 and that their opposition is currently due on or before May 13, 2022. They ask that the response be extended through May 23, 2022, and state that counsel for the defendants have no objection. The motion gives as a reason that the Motion and Brief totaled more than 70 pages.

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       Case 4:21-cv-01243-BRW           Document 47         Filed 05/04/22   Page 1 of 2




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


  ERIC GREATHOUSE, ERNESTO
  COVARRUBIAS, TIFFANY SUMRALL,
  AND BARBARA MYLES, individually and
  on behalf of all others similarly situated,         Case No. 4:21-cv-01243-BRW


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

                 Defendants.



       Plaintiffs Eric Greathouse, Ernesto Covarrubias, Tiffany Sumrall, and Barbara Myles,

individually and on behalf of all others similarly situated, for their Unopposed Motion for

Extension of Time To File a Response to Defendants’ Motion to Dismiss, state as follows:

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

Motion to Dismiss and Brief in Support (Doc. Nos. 44 & 45) on April 29, 2022 (the “Motion”).

       2.      Plaintiffs’ opposition to the Motion is currently due on or before May 13, 2022.

       3.      Plaintiffs request that their response to the Motion be extended for an additional

period of time through May 23, 2022, and that an Order be entered reflecting the same.

       4.      Counsel for Defendants have no objection to Plaintiffs’ requested extension.

       5.      This extension is sought so that Plaintiffs may fully and adequately respond to the

arguments presented in Defendants’ Motion and Brief which totaled more than 70 pages, is made

in good faith, and is not for the purpose of undue delay.
       Case 4:21-cv-01243-BRW            Document 47        Filed 05/04/22       Page 2 of 2




       WHEREFORE, Plaintiffs Eric Greathouse, Ernesto Covarrubias, Tiffany Sumrall, and

Barbara Myles, individually and on behalf of all others similarly situated, pray that this Court grant

their Unopposed Motion for Extension and that they be awarded any additional relief as may be

just and proper.



Dated: May 4, 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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