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Federal Trade Commission v. Consumer Defense, LLC

United States District Court, D. Nevada

May 17, 2019

FEDERAL TRADE COMMISSION, Plaintiff,
v.
CONSUMER DEFENSE, LLC, et. al., Defendants.

          DEFENDANTS REQUEST FOR ADDITONAL TIME TO REPLY

          BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE

         Defendant, Jonathan Hanley (“Hanley”), in respectfully asking that this court grant him 7 additional days to respond to Plaintiff FTC's Motion to Determine Sufficiency of Answers states as follows:

         The nature and importance of this motion have required a substantial amount of time to craft a proper response. Hanley has prepared a response in connection with the portion of the motion that corresponds to the FTC Firsts Request for Admission of Fact. The response is written but requires further perfection concerning exhibits and a Declaration. The draft response is attached. (Hanley Decl. Att. A.)

         The research has been commenced for crafting a proper response to the part of the motion at bar concerning the FTC's second request for admission of fact, but a version that is suitable for filing is not even close to being ready.

         This is the first request for an extension of time to file a pleading that Hanley has made during the pendency of this litigation. Hanley sent counsel for FTC an e-mail requesting additional time, but it was sent very late in the evening.

         The breadth of motion practice that is occurring at this point in the litigation is substantial and time consuming. Hanley is pro se and while he should be held to the same standards as opposing counsel the logistics of effectively handling this litigation with the Motion Practice at hand is very difficult.

         Accordingly, I ask this Court grant 7 additional days, or until May 22n to reply to The FTC's Motion to Determine Sufficiency of Answers.

         IT IS SO ORDERED

         DEFENDANTS OPPOSITION TO PLAINTIFFS MOTION TO DETERMINE THE SUFFICIENCY OF ANSWERS TO REQUEST FOR ADMISSION

         Defendant Jonathan Hanley (“Hanley”) opposes Plaintiff Federal Trade Commission's (FTC) Motion to Determine the Sufficiency of Answers to Requests for Admission and respectfully requests that this Court deny the motion. A proposed order is attached. In opposition of the Motion Hanley states as follows:

         I. Background

         The FTC files this motion in connection with Hanley's timely responses to 556 Request for Admission of Fact. In their background statement (ECF. No. 208 at 2:13- 17) the FTC represents to this Court that their second request for admission was served on December 26th 2018 and then ultimately responded to on February 27th 2018. The FTC misrepresents this fact to the Court as the actual response was served in a timely manner on January 24th 2019. (Hanley Decl. ¶ 3.)

         The FTC further misrepresents the facts of the case at this point. Their complaint certainly makes very serious allegations against the defendants. These allegations are misguided and wrong. The FTC has already responded to hundreds of Hanley requests for admission wherein consumer received modified mortgages with features such as 0% to 3% interest rates, millions of dollars of forgiven principal, tens of millions of dollars of deferred principal and mortgage payments wherein the savings to consumers typically ranged from 20% to 40% savings. This litigation is abusive and a perversion of the unchecked powers that are at the FTC's disposal. It is important to note that the FTC is now vehemently attempting to avoid responding to additional meritorious requests for admission that have been propounded by Hanley. Their evasive tactics have been raised in a pending Motion for Extension of Discovery that has been filed by Hanley. (ECF No. 216.)

         II. MEET AND CONFER EFFORTS ...


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