Case 2:11-cv-01426-GMS Document 20 Filed 10/05/11 Page 1 of 3

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Quarles & Brady LLP

Firm State Bar No. 00443100 Renaissance One, Two North Central Ave. Phoenix, AZ 85004-2391
TELEPHONE 602.229.5200

John S. Craiger (#021731) John.Craiger@quarles.com David E. Funkhouser III (#022449) David.Funkhouser@quarles.com Krystal M. Aspey (#026609) Krystal.Aspey@quarles.com Attorneys for Defendant Lisa Jean Borodkin IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA XCENTRIC VENTURES, LLC, an Arizona limited liability company, Plaintiff, v. LISA JEAN BORODKIN and JOHN DOE BORODKIN, husband and wife; RAMOND MOBREZ and ILIANA LLANERAS, husband and wife; DANIEL BLACKERTS and JANE DOE BLACKERTS, husband and wife; ASIA ECONOMIC INSTITUTE, LLC, a California limited liability company, DOES 1-10, inclusive, Defendants. For the reasons identified below, Defendant Lisa Jean Borodkin ("Ms. Borodkin") moves this Court for an extension of time, through and including October 31, 2011, by which she must file an answer or response to Plaintiff's Complaint. A proposed form of order is being submitted herewith. On October 4, 2011, counsel undersigned served Plaintiff's counsel with a Motion for Sanctions pursuant to Federal Rule of Civil Procedure 11 (the "Rule 11 Motion"). No. 2:11-CV-01426-PHX-GMS DEFENDANT LISA JEAN BORODKIN'S MOTION FOR EXTENSION OF TIME TO ANSWER/RESPOND (Assigned to the Honorable G. Murray Snow) (Expedited Consideration Requested)

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Pursuant to the "safe harbor" provisions contained in Fed. R. Civ. P. 11(c)(2), Ms. Borodkin must allow Plaintiff twenty-one days after service of the Rule 11 Motion to withdraw or otherwise correct the Complaint in this action before she may present the Rule 11 Motion to the Court. In the interests of judicial economy, as well as to avoid the incurrence of additional unnecessary legal fees, counsel undersigned requested that Plaintiff's counsel agree and stipulate to a reasonable extension of time for Ms. Borodkin to answer or respond to the Complaint while Plaintiff and counsel consider the Rule 11 Motion. However, Plaintiff's counsel denied this request.1 Accordingly, Ms. Borodkin now requests the same relief from this Court. It may further be noted that, upon information and belief, at least one key party, defendant Daniel Blackert, has not yet been served with the Complaint in this action. Accordingly, Plaintiff's case would not be prejudiced or unduly delayed by the reasonable extension requested by Ms. Borodkin. For the above reasons, Ms. Borodkin respectfully requests that the Court grant her an extension of time, through and including October 31, 2011, by which she must file an answer or response to Plaintiff's Complaint. RESPECTFULLY SUBMITTED this 5th day of October, 2011. QUARLES & BRADY LLP Renaissance One, Two North Central Avenue Phoenix, AZ 85004-2391 By /s/ David E. Funkhouser III John S. Craiger David E. Funkhouser III Krystal Aspey Attorneys for Lisa Jean Borodkin
It is important to note that Plaintiff's counsel, David Gingras, did provide Ms. Borodkin with an initial extension in this matter from September 21, 2011 through and until October 5, 2011, after undersigned counsel's firm was retained to defend Ms. Borodkin in this matter.
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CERTIFICATE OF SERVICE I hereby certify that on October 5, 2011, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: David S. Gingras, Esq. (David@GingrasLaw.com) Attorneys for Plaintiff Hartwell Virginia Harris (hartwell@hartwellharris.com) Attorney for Defendants Mobrez, Llaneras and Asia Economic Institute LLC /s/ David E. Funkhouser III

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