Bronstin v. ViaSat, Inc. — Entry #76: Unopposed MOTION for Extension of Time to File Response to Second Amended Complaint by The Preferred Prepaid, Inc., ViaSat, Inc

Case 1:25-cv-00927-KMN           Document 76         Filed 07/16/26      Page 1 of 3


                     IN THE UNITED STATES DISTRICT COURT
                   FOR THE MIDDLE DISTRICT OF PENNSYLVANIA


 ASHER BRONSTIN, individually and on
 behalf of all other similarly situated,

 Plaintiff,
                                                   Civil Action No. 1:25-cv-00927-KMN
 v.
                                                   (Hon. Keli M. Neary)
 VIASAT, INC.,

 and

 THE PREFERRED PREPAID, INC.
 d/b/a XYZies

 Defendants.


UNOPPOSED MOTION TO EXTEND TIME FOR DEFENDANTS TO FILE RESPONSE
                TO SECOND AMENDED COMPLAINT

       Defendants Viasat, Inc. (“Viasat”) and The Preferred Prepaid, Inc. d/b/a XYZies

(“XYZies”), collectively (“Defendants”) respectfully submit this unopposed motion to extend the

time by which Defendants must submit a response to Plaintiff’s Second Amended Complaint (see

Dkt. 70, “SAC”), to August 12, 2026. In support thereof, Defendants states the following:

       1.      Plaintiff filed his SAC in this action on June 11, 2026. See Dkt. 70.

       2.      On June 18, 2026, the Court ordered that Viasat’s deadline to respond to the SAC

shall be extended to the same deadline applicable to XYZies following service, so that both

defendants may respond on the same schedule. See Dkt. 723.

       3.      On June 27, 2026, XYZies was served with a copy of the SAC.

       4.      According to the Federal Rules of Civil Procedure 12 and 15, XYZies deadline to

respond to the SAC is July 20, 2026.

       5.      On July 14, 2026, XYZies counsel, Joe Samo, requested an extension of XYZies


        Case 1:25-cv-00927-KMN                 Document 76          Filed 07/16/26         Page 2 of 3


response deadline to August 12, 2026.1

        6.       Plaintiff’s counsel agreed to extend XYZies and Viasat’s deadline to respond to the

SAC to August 12, 2026.

        7.       Pursuant to the requested and agreed to extension, if granted, Defendant’s new

deadline to answer, move or otherwise respond to the SAC would be August 12, 2026.

        8.       This is the Defendants’ first request for an extension of this deadline.

        9.       No other case deadlines will be impacted by the requested extension.

        10.      This motion is made in good faith and not for the purpose of delay.

        11.      No party to this action will be unduly prejudiced by the granting of the requested

extension of time, especially as the parties are in agreement. An extension will not impact the

timely resolution of this matter, or any other deadlines, as this case is still in its early stages.

        12.      Thus, Defendants respectfully submits that there is sufficient “good cause” to grant

the requested extension, for at least the reasons provided above.

        WHEREFORE, for all of the reasons above, Defendants respectfully request that the Court

enter an order extending its deadline to answer, move or otherwise respond to the SAC would be

August 12, 2026. A proposed order has been included for the Court’s consideration.


Dated: July 16, 2026               Respectfully submitted,

                                                     By: /s/ A. Paul Heeringa

                                                     (Admitted Pro Hac Vice)
                                                     MANATT, PHELPS & PHILLIP, LLP
                                                     1050 Connecticut Avenue, NW, Suite 600
                                                     Washington, D.C. 20036
                                                     Telephone: 202-585-6500
                                                     jmcguinness@manatt.com
                                                     pheeringa@manatt.com

1
  Although Mr. Samo has not formally entered an appearance in this matter he has agreed to allow his signature on
this motion.

                                                        2


       Case 1:25-cv-00927-KMN             Document 76         Filed 07/16/26       Page 3 of 3


                                                FREDERICK P. SANTARELLI (PA 53901)
                                                STEVEN C. TOLLIVER, JR. (PA 327165)
                                                ELLIOTT GREENLEAF, P.C.
                                                Union Meeting Corporate Center V
                                                925 Harvest Drive, Suite 300
                                                Blue Bell, PA 19422
                                                (215) 977-1000 (phone)
                                                FPSantarelli@elliottgreenleaf.com
                                                sct@elliottgreenleaf.com

                                                Counsel for Defendant Viasat, Inc.

                                                By: /s/ Joe Samo

                                                Counsel for Defendant XYZies


                                  CERTIFICATE OF SERVICE

        I hereby certify that, on July 16, 2026, I filed the foregoing electronically through the Court’s

CM/ECF system, which caused the following parties or counsel to be served by electronic means on

all parties and their respective counsel of record.


                                                                /s/ A. Paul Heeringa


                                                      3