Ramirez v. Experian Information Solutions, Inc.

CRAIG FRIEDBERG, ESQ.

Nevada Bar No. 4606 Law Offices of Craig Friedberg, Esq.

4760 South Pecos Road, Suite 103 Las Vegas, Nevada 89121 Phone: 702.435.7968 [email protected] JAMES M. SMITH, ESQ. (IL Bar No: 6285183) Pro hac vice to be submitted Doherty Smith, LLC 7000 W. 127th Street Palos Heights, IL 60463 Phone: 312.319.2879 Fax: 312.319.4084 [email protected] Attorneys for Plaintiff 11 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA ARTURO RAMIREZ, ) ) 14 Plaintiff, ) Case No: 2:25-cv-1460-JCM-NJK ) 15 v. ) 16 ) PLAINTIFF’S MOTION TO EXTEND EXPERIAN INFORMATION SOLUTIONS, ) TIME TO FILE VERIFIED PETITION INC., EQUIFAX INFORMATION SERVICES, ) AND DESIGNATION OF LOCAL LLC, and TRANS UNION LLC., ) COUNSEL ) (First Request) 19 Defendants. ) 22 Arturo Ramirez (“Plaintiff”) by and through his counsel, moves this Court for an extension of time to file attorney James M. Smith’s Verified Petition and Designation of Local Counsel pursuant to LR IA 11-2 on or before September 19, 2025. In support thereof, Plaintiff states as follows: 26 1. On August 7, 2025, Plaintiff filed his Verified Complaint stating attorney James M. Smith would be submitting his Verified Petition and Designation of Local Counsel in this 1 2. On August 8, 2025, this court entered an Order ordering attorney James M.

2 || Smith to file his Verified Petition and Designation of Local Counsel on or before August 22, || 2025. [ECF 3].

4 3. Pursuant to LR JA 11-2(b)(3), the Verified Petition and Designation of Local Counsel must include an attached certificate of good standing for the attorney seeking |}admission in a particular case. Attorney James M. Smith has ordered certificates of good || standing from the Illinois Supreme Court and the United States Northern District of Illinois; || however, he is still waiting to receive the certificates through postal mail.

9 4. Consequently, Plaintiff is requesting an additional 28 days to file attorney James ||M. Smith’s Verified Petition and Designation of Local Counsel, on or before September 19, |} 2025.

12 5. This is the first request for an extension of time to file James M. Smith's Verified || Petition and Designation of Local Counsel.

14 WHEREFORE, based on the foregoing, Plaintiff Arturo Ramirez respectfully requests || that this Honorable Court grant Plaintiff and his counsel an extension of 28 days, through and || including September 19, 2025, for James M. Smith to file his Verified Petition and Designation || of Local Counsel for admission pro hac vice.

18 || Dated: August 21, 2025 Respectfully submitted, 19 Law Offices of Craig Friedberg, Esq.

20 By: /s/ Craig Friedberg Craig Friedberg, Esq.

James M. Smith (pro hac vice to be submitted) Doherty Smith, LLC 7000 W. 127" Street Palos Heights, IL 60463 23 JSmith @dohertysmith.com 24 Attorneys for Plaintiff IT IS SO ORDERED.

26 aA a (tid AtLg be 27 UNITED STATES DISTRICT JUDGE