Joint Stipulation for Extension of Time for Defendant Lexisnexis Risk Solutions Inc. to Respond to Plaintiff’s Complaint — Kaitlyn Rose Slaughter v. Lexisnexis Risk Solutions Inc. (Dkt. 11, D. Colo.)

Summary

A joint stipulation for extension of time for defendant LexisNexis Risk Solutions Inc. to respond to the complaint in Kaitlyn Rose Slaughter v. LexisNexis Risk Solutions Inc., Case No. 1:23-cv-02566-CNS-SKC, in the U.S. District Court for the District of Colorado, filed November 1, 2023 (Document 11). Under Federal Rule of Civil Procedure 6(b)(1)(A) and Local Civil Rule 6.1, the parties recite that the complaint was filed October 2, 2023 (ECF No. 1), that service was made October 16, 2023 and that the response is due November 6, 2023, and they stipulate to the one extension of up to 21 days the local rule allows. Service is certified by Nicole K. Serfoss, attorney for the defendant.

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Case No. 1:23-cv-02566-CNS-SKC Document 11 filed 11/01/23 USDC Colorado pg 1 of 4




                             UNITED STATES DISTRICT COURT
                             FOR THE DISTRICT OF COLORADO


  KAITLYN ROSE SLAUGHTER,

             Plaintiff,
                                                       Case No. 1:23-cv-02566-CNS-SKC
  v.

  LEXISNEXIS RISK SOLUTIONS INC.,

             Defendant.


   JOINT STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT LEXISNEXIS
        RISK SOLUTIONS INC. TO RESPOND TO PLAINTIFF’S COMPLAINT

         Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A) and District of Colorado Local

  Civil Rule 6.1, Plaintiff Kaitlyn Rose Slaughter and Defendant LexisNexis Risk Solutions Inc.

  (“LexisNexis Risk”), by and through their respective counsel, hereby stipulate as follows:

         WHEREAS, Plaintiff filed the above-captioned action against LexisNexis Risk on October

  2, 2023 (the “Complaint”) (see Compl., ECF No. 1);

         WHEREAS, Plaintiff effectuated service on LexisNexis Risk on October 16, 2023;

         WHEREAS, pursuant to Rule 12(a) of the Federal Rules of Civil Procedure, LexisNexis

  Risk’s responsive pleading is due on November 6, 2023;

         WHEREAS, D.C.COLO.LCivR. 6.1(a) provides that “[t]he parties may stipulate in writing

  to one extension of not more than 21 days beyond the time limits prescribed by the Federal Rules

  of Civil Procedure to respond to a pleading or amended pleading, interrogatories, requests for

  production of documents, or requests for admissions. The stipulation must be filed before the

  expiration of the time limits to respond prescribed in the Federal Rules of Civil Procedure and

Case No. 1:23-cv-02566-CNS-SKC Document 11 filed 11/01/23 USDC Colorado pg 2 of 4




  shall be effective on filing, unless otherwise ordered.”;

         WHEREAS, pursuant to D.C.COLO.LCivR. 6.1, Plaintiff and LexisNexis Risk agree to

  extend LexisNexis Risk’s time to respond to Plaintiff’s Complaint by twenty-one (21) days,

  through and including November 27, 2023;

         WHEREAS, on October 25, 2023, counsel for LexisNexis Risk conferred with counsel for

  Plaintiff, who agreed to the 21-day extension to allow LexisNexis Risk time to secure local counsel

  and to locate documents that would allow it to meaningfully respond to Plaintiff’s Complaint;

         WHEREAS, this is the first request for an extension by the parties;

         WHEREAS, this request is made in good faith and not for any improper purpose, and this

  extension would not prejudice any party to the litigation;

         WHEREAS, pursuant to D.C.COLO.LCivR. 6.1(c), counsel for LexisNexis Risk certifies

  that a copy of this stipulation is served on the client; and

         WHEREAS, by entering into this Stipulation, LexisNexis Risk does not waive, and

  specifically preserves, any and all defenses available to it under Federal Rule of Civil Procedure

  Rule 12 and otherwise;

         NOW THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff and

  LexisNexis Risk, through their respective attorneys of record, that LexisNexis Risk may respond

  to the Complaint on or before November 27, 2023.

Case No. 1:23-cv-02566-CNS-SKC Document 11 filed 11/01/23 USDC Colorado pg 3 of 4




         Respectfully submitted this 1st day of November, 2023.


                                         /s/ Nicole K. Serfoss
                                         Nicole K. Serfoss, CO Bar #36815
                                         MORRISON & FOERSTER LLP
                                         4200 Republic Plaza
                                         370 Seventeenth Street
                                         Denver, CO 80202-5638
                                         P: 303-592-1500
                                         F: 303-592-1510
                                         nserfoss@mofo.com

                                         Attorney for Defendant
                                         LexisNexis Risk Solutions Inc.



                                         /s/ James Ristvedt
                                         James Ristvedt, AZ Bar #035938
                                         CONSUMER ATTORNEYS
                                         8245 N. 85th Way
                                         Scottsdale, AZ 85258
                                         T: 480-626-1956
                                         jristvedt@consumerattorneys.com

                                         Attorney for Plaintiff
                                         Kaitlyn Rose Slaughter

Case No. 1:23-cv-02566-CNS-SKC Document 11 filed 11/01/23 USDC Colorado pg 4 of 4




                                   CERTIFICATE OF SERVICE

          This is to certify that on November 1, 2023, I electronically filed the foregoing pleading

  with the Clerk of the Court using the CM/ECF system which will automatically send an email

  notification of such filing to all attorneys of record.


                                                  /s/Nicole K. Serfoss
                                                  Nicole K. Serfoss

                                                  Attorney for Defendant
                                                  LexisNexis Risk Solutions Inc.

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