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DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
MARK A ADAMS,
Appellant,
Appellees.
_______________________________/
and through their undersigned counsel, move this Court for the entry of an Order
on the attached list and extending the time for Appellees to file and serve their
answer brief to one week after the transmittal of the supplemental record, and as
upon Appellant’s intentional refusal to answer the Complaint after being given at
least four opportunities. Appellant also seeks relief from the subsequent Order
Denying Discharge of Debtor entered on April 23, 2008 in Bankruptcy Case No.
Proceeding.
2. After initiating this appeal, Appellant failed to file and serve a
Clerk of the Bankruptcy Court transmitted a limited record to this Court on August
3. After Appellant failed to file his initial brief on time, this Court
entered an Order directing Appellant to file his initial brief on or before September
8, 2008. (Doc. 6)
complained that the Clerk of the Bankruptcy Court had not transmitted a
that the “entire record on appeal” be filed with the Clerk of this Court on or before
transmitted.
than transmitting the entire record ordered by this Court, only transmitted the
appeal raises entirely procedural issues, the procedural course of the case is
important for a full exposition. Also, Appellant has omitted important and
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significant documents, such as the complaint and amended complaint in the
adversary proceeding, documents evidencing that Appellant did not timely file his
extension of time, and many other extensions of time sought and obtained by
Appellees would request that this Court enter an Order directing the Bankruptcy
Clerk to transmit to this Court the items identified on the attached list.
10. Appellees have been diligently preparing the Answer Brief but will
not be able to conclude the brief with appropriate record citations until after the
record is supplemented. Appellees would request that the Court allow one week
following the supplementation of the record for Appellees to file and serve the
Answer Brief.
INC. et al., move this Honorable Court for the entry of an Order permitting
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supplementation of the record and extending the briefing schedule and granting
CERTIFICATE OF SERVICE
foregoing with the Clerk of Court by using the CM/ECF system. I further certify
that I mailed the foregoing document and the notice of electronic filing by first-
s/ Timothy W. Weber
TIMOTHY W. WEBER, ESQUIRE
Florida Bar No. 86789
Battaglia, Ross, Dicus & Wein, P.A.
Wachovia Bank Building
980 Tyrone Boulevard
P.O. Box 41100
St. Petersburg, Florida 33743
(727) 381-2300
(727) 343-4059 (facsimile)
twebe@brdwlaw.com
Attorneys for Appellees
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U.S. Bankruptcy Case No. 8:05-bk—29501-PMG
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3 Amended Complaint
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