Plaintiff QSGI, Inc. filed a motion for a 10-day extension of time to file its response to Defendants IBM Global Financing and International Business Machines Corp.'s motion to dismiss the second amended complaint. Plaintiff's counsel has been away from the office for depositions in other cases over the past two weeks and will be out of the office again taking a deposition. While Defendants oppose the extension, Plaintiff is requesting more time due to counsel's busy schedule.
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Plaintiffs Motion for Extension of Time to file Response to Defendants Motion to Dismiss Second Amended Complaint
Plaintiff QSGI, Inc. filed a motion for a 10-day extension of time to file its response to Defendants IBM Global Financing and International Business Machines Corp.'s motion to dismiss the second amended complaint. Plaintiff's counsel has been away from the office for depositions in other cases over the past two weeks and will be out of the office again taking a deposition. While Defendants oppose the extension, Plaintiff is requesting more time due to counsel's busy schedule.
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Plaintiff QSGI, Inc. filed a motion for a 10-day extension of time to file its response to Defendants IBM Global Financing and International Business Machines Corp.'s motion to dismiss the second amended complaint. Plaintiff's counsel has been away from the office for depositions in other cases over the past two weeks and will be out of the office again taking a deposition. While Defendants oppose the extension, Plaintiff is requesting more time due to counsel's busy schedule.
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Attribution Non-Commercial (BY-NC)
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Téléchargez comme PDF, TXT ou lisez en ligne sur Scribd
No.09:1l-cv-80880-KLR QSGI, Inc., a Delaware Corporation, Plaintiff, v. IBM GLOBAL FINANCING, a Division of International Business Machines Corp., and INTERNATIONAL BUSINESS MACHINES CORP., Parent to andlor d/bla IBM GLOBAL FINANCING, Defendants. __________________________ ~ I PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS' MOTION TO DISMISS SECOND AMENDED COMPLAINT Plaintiff, by and through undersigned counsel, hereby files this Motion for Extension of Time to File Response to Defendants' Motion to Dismiss Second Amended Complaint pursuant to Fed. R. Civ. P. 6(b)(I) and Local Rule 7.1. In support thereof, Plaintiff states as follows: 1. Plaintiffs Response to Defendants' Motion to Dismiss Second Amended Complaint is due Thursday, May 3, 2012. 2. Plaintiff's counsel responsible for drafting Plaintiff s Response has been away from his office eight (8) out of the preceding ten (10) busim-ss days covering depositions in two separate lawsuits set for trial in Boston, Massachusetts and Ft. Lauderdale, Florida. See, Robert Stead et al. v. Georgia-Pacific LLC; Case No. 09-4917, Superior Court for Middlesex County, Massachusetts; and Donald Bolton et al. v. ACandS, Inc., Cale No. 00-10831, In the 17 th Judicial Circuit in and for Broward County, Florida. Plaintiffs cO'lllsel will also be out of the office taking the videotaped deposition of a dying client outside of)eltona, Florida, April 30 to May 2, Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 1 of 3 2012. See, Bernard Harmon et al. v. Borg Warner Corp., Caf:e No. 11-4289, In the 17'h Judicial Circuit in and for Broward County, Florida. 3. Given Plaintiffs counsel's inconvenient sch,:dule during the past and coming weeks Plaintiff requests a short ten (10) day extension of 1ime to file Plaintiffs Response to Defendants' Motion to Dismiss Second Amended Complaint. 4. This is Plaintiff first request for an extension of time to file its Response to Defendants' Motion to Dismiss Second Amended Complaint. 5. Plaintiffs counsel conferred with Defendants counsel, and Defendants object to Plaintiffs request for a 10-day extension of time to file Plaintiffs Response. WHEREFORE, for the reasons set forth herein, Plaintiff respectfully requests that this Court enter an Order Granting Motion for Extension of Time to File Response to Defendants' Motion to Dismiss Second Amended Complaint. By: Respectfilll y submitted, THE FERRARO LAW FIRM, P.A. AttorneYifor the Plaintiff 4000 Por:ce de Leon Blvd. Suite 70( Miami, FL 33146 Telephone (305) 375-0111 Facsimik (305) 379-6222 ("' __ _ 2 CASE A DAM, ES . Florida Bar No. 756091 Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 2 of 3 ------------------ ---- CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the for egoing was served via CMlECF on all counsel of record this C THE . . } . ..
Florida Bar No. 756091 3 Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 3 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 11-80880-CIV-RYSKAMP\vITUNAC QSGI, Inc., a Delaware Corporation, Plaintiff, v. IBM GLOBAL FINANCING, et al. Defendants. - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ / ORDER GRANTING PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO DEFENDANTS' MOTION TO DISMISS SECOND AMENDED COMPLAINT THIS CAUSE having come before the Court on Plain:iff's Motion for Extension of Time to File Response to Defendants' Motion to Dismiss Second Amended Complaint and the Court having considered Plaintiff's Motion and being fully advised in the premises, it is hereupon: ORDERED AND ADJUDGED: I. Plaintiff's Motion is GRANTED. 2. Plaintiff shall file its Response to Defendants' Motion to Dismiss Second Amended Complaint on or before May 14,2012. DONE AND ORDERED in Chambers at West Palm Beach, Florida, this ___ day of ____________ ,,2012. KENNE'cH L. RYSKAMP UNITED STATES DISTRICT JUDGE Case 9:11-cv-80880-KLR Document 60-1 Entered on FLSD Docket 04/27/2012 Page 1 of 1
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