BASIS FOR REQUEST FOR EXTENSION

Counsel for the Defendant has indicated that the Defendant needs additional time to review the Complaint in this matter. Time is further needed for the parties to discuss the possible resolution of this matter. If a resolution can be reached in this matter, most likely such a resolution would be a global resolution that would resolve this case in its entirety as to all the parties.

With the above in mind, Plaintiff seeks an extension of time for Defendant to respond to the Complaint not for delay, but to, among other things, permit the parties an opportunity to resolve Plaintiff’s claims without the need for further litigation.