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DoctorS, Good to see your still around from Yesterday's post. I think we will have a better (positive) understanding shortly.
Vern what's wrong? Did you and Joe lose your info line (Tim).
I'm curious as to why your leaving know, care to share?
IMHO. I think JOEJ (pronounced like OJ) was getting inside info on both sides of the spectrum. Good things and Bad things. But was relentless in his pursuit to drive the share price down. Come on Vern, how many shares did you and JoeJ pick up over the last 3 weeks? If JoeJ was getting the negative stuff, surely he was getting the positive stuff as well. I'll agree with your earlier Post that Sans 2A is probably being dismantled on the Hanger floor today. Would you care to share with us where it's being transported to? Or should we just wait for the PR. Vern I hope you where Smart enough not to Buy any shares recently with your inside info through JoeJ and Tim. Federal Prosecutors will bury you in legal fee's. There is always the option to being a star witness against JoeJ.
Vern your too Freaking old to mess with this stuff.
(In Tims defense, he's doesn't have a vindictive bone in his body. Just a little naive.)
"GTEM ignored a court order"
What Court Order? My understanding it is a Contract for payment between the City of LA and Sanswire.
It's working fine on E*Trade
Last 7500 .1275 at 11:18:04
With his profile, Im sure cooking the Books.
Just in California alone he moved from
1201 Chelsea way in Redwood, CA
555 Hiller Dr in Oakland, CA
210 Clay st in Oakland, CA
Also San Carlos, CA
Menlo Park, CA
and San Francisco, CA
Anyone who bounces around that much is trying to get away from something.
I love this part of Joes letter to the Company Board of Directors, He was asking to Be CEO of the Whole Company and got rejected.
However I cannot stay with the company under the current management and direction the company appears to be taking. I did not ask for the COO position and was extremely reluctant in accepting it. It was clear to me after a few visits to the corporate offices that the company needed the discipline and management style I could bring. These are the same strengths I will bring to the CEO position I have never quit or refused a challenge; I have been in business for more than forty years and cannot see a short term solution other than to take this on myself. I have given this situation a great deal of thought and believe that we can be profitable within 180 days if changes are made immediately.
I can be reached at 954-675-4449 (C), or 954-476-7983 (H)
I guess this email from Joe to Vern answers the question if Joe has someone helping him create his New Website.
----- Original Message -----
From: monterosso2007-i...@yahoo.com
To: Vernon Koenig
Sent: Monday, September 03, 2007 11:42 AM
Subject: web site
Vern,
I think it's the perfect time to post a web site url we put up today that will undercut Quick Stock response. We will add more to it tomorrow and as necessary.
Joe Monterosso
Joseph Monterosso
Cell:954-826-0572
In case you wanted to see.
From Pacer regarding the Class Action Lawsuit Settlement
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No. 06-21071-CIV-ALTONAGA/Turnoff
RICHARD STEVENS, et al., on behalf of
themselves and all others similarly situated,
Plaintiffs,
v .
GLOBETEL COMMUNICATIONS CORP.,
et al.,
Defendants.
ORDER
THIS CAUSE comes before the Court upon the parties’ Notice of Joint Report of Settlement
and Motion to Continue Stay of Proceedings (the “Motion to Stay”), filed on September 11, 2007
[D.E. 71]. On June 12, 2007, the Court stayed this action pending the parties’ effort at mediation.
The Court has been informed that on August 23, 2007, the parties mediated their claims and
tentatively agreed to the settlement of this class action. The parties also inform that they are presently
drafting a settlement agreement and various ancillary documents necessary for the final settlement of
this class action pursuant to Rule 23 of the Federal Rules of Civil Procedure. Accordingly, the parties
propose a continued stay of this action for 45 days (until October 26, 2007) so that they may have
sufficient time to finalize the settlement and present it to the Court for approval.
Based on the parties’ representations, pertinent portions of the record, and being otherwise
fully informed in the premises, it is hereby ORDERED AND ADJUDGED that the parties’ Motion to Stay [D.E. 71] is GRANTED.
This action is further stayed until October 26, 2007, in order to give the parties sufficient time to
finalize the settlement and present it to the Court for approval. All dates contained in the Court’s
May 10, 2007, Order Setting Trial and Pre-trial Schedule, Requiring Mediation, and Referring Certain
Motions to Magistrate Judge are tolled accordingly. No further extensions are permitted.
DONE AND ORDERED in chambers in Miami, Florida, on this 11th day of September,
2007.
_______________________________
CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
General Mass Email from IR:
From: Rob Bleckman Sent: Thursday, September 06, 2007 8:01 AM
To: 'R Bleckman'
Subject: Response from GlobeTel
The unprecedented, extremely high volume of phone calls and emails, along with a heavy work load, prevents me from providing personal answers to individual emails at this time.
I think most of you who have communicated with me before know how much I dislike these all-purpose, boilerplate responses. I don’t like receiving them as a shareholder either, but you deserve a timely response to your email and it’s really the only way right now that I can let you know that your concerns about issues such as share price, the CEO, the Mexican joint venture, continued harassing and libelous statements on the message boards, compliance and financial results, and of general conditions within the Company are all of critical importance to me, and to the management, and will be addressed directly by the Company via the ONLY avenues for disseminating news that we have available to us-- press releases and SEC filings.
I know asking for your patience right now is a very tall order, but please bear with us during this time.
Sincerely,
Rob Bleckman
Director, Investor Relations
GlobeTel Communications Corp.
(954) 607-1295
It's my understanding you must have three Undisputed Claims to even file an involuntary bankruptcy.
Who are the three with Undisputed Claims?
I called E*Trade on Tuesday to find out where my stocks had been placed. Even though I bought with Cash, they placed it into a Type 2 Account (margin). They just sent me these messages saying they transfered all the shares back to a Type 1 Account (Cash)
Account: Brokerage - XXXX
Date posted: 08/01/2007
Description: GLOBETEL COMMUNICATIONS CORP Transfer FROM TYPE 2
Account: Brokerage - XXXX
Date posted: 08/01/2007
Description: GLOBETEL COMMUNICATIONS CORP Transfer TO TYPE 1
Just a heads up, when I first called E*Trade, the rep was quick to assume that since I bought the stock with Cash that they would not be held in a Margin account. It took him a few minutes to realize they where in a margin account. My advice for anyone who wants to check there E*Trade account. Ask them if the shares you have are being held in a Type 1 (Cash) or type 2 (Margin) account.
You forgot one.
"Mo Mas Vern" as of July 27 12:01 pm Est...
Great News! Lot's of green on Level II , and Vern will dismiss himself from all boards this Friday at 12:00 noon EST.
Vern's Promise #81616
"I'm going to make a prediction. I predict that by this time (12:00 noon EST) next Friday, July 27th, that information YOU find out on your OWN will be made public and will cause GTEM shareprice to plummet to .15 cents or lower.
If that doesn't happen, I'll never post on this or any board having to do with GTEM. I am THAT SURE of what I say here and now! I predict that GTEM will take a major shareprice hit when that news avails itself.
Thanks for posting that update. If this is only a status hearing, Vern is going to be very disappointed with the two minute brief interaction between the lawyers and Judge. In fact, unless he is standing next to one of the lawyers he won't hear a thing.
Everyone be prepared for Verns Spin tomorrow. Remember he just posted this statement a few post back.
"Tomorrow will be the big fandango in Lancaster. I plan to be there and watch the County of Los Angeles bust Sanswire's pinata"
Your going to waste your time Vern. It's going to be continued for another 45-60 days. Have a Safe trip Vern.
That case is is settlement discussions. I don't think Huff or Globetel will have to say anything in court. IMO
More than likely Vern got some direct information from Uli regarding the countersuit that was, or is going to be filed.
There is nothing unusual about the 20 million countersuit ( you can place any figure to the Countersuit) But, what will likely happen is Mr.LeinWand will file an action to Dismiss the countersuit of "Defamation and Slander" and this case will only be about the Contract Dispute.
IMO.
ColeThorton did you really just use."Bill Gates, Michael Dell, Sam Walton, etc... etc..." when talking about Vern?
If Vern was Ceo of Globetel (ROFLMAO)...
Who would be the Shareholders. You, followingte and Jimprofit. LOL!
I've got a hunch that Mr.Leinwand would be interested in this public statement by Vern.
My plans are no secret. When GTEM goes into Chapter 7, I plan to buy the shell. It is a listed corporation and my company is virtually debt free. I plan to reverse into GTEM and rename the company Stratodyne-Globetel
Uh.. Vern? How can you go from one extreme to the other and be taken seriously? You Vern, are going to save us??
Posted by: vkoenig
In reply to: None Date:4/6/2007 5:29:48 PM
Post #of 80558
"Obviously the Peralta family has enough business foresight to see that GTEM is a potential little goldmine for them. Mexicans don't risk their money unless it is a sure bet. The Peralta's didn't get wealthy by being stupid. My thinking is: If it is good enough for the Peralta's, then it must be good for me. I wouldn't be the least bit surprised if the Peralta's back the Strat. Think about it!"
The Peralta's aren't a charitable organization - they are a money-making 'family organization'....one of 15 in Mexico. If they can 'best' the other 14 families, then so be it. Not only does the Hotzone system appeal to them, then the Strat might appeal even more....especially if they were built in Mexico and distributed throught Mexico, Central and South America. Think about that too!
"and Murch in California."
Thanks for confirming Doug is working hard in California on the Stratellite and SkySat. Someone was posting a rumor he left.
Actually it's 8000 homes not 8000 people.
"an 8,000-home community in the Mexico City suburb of Tizayuca" (Probably 20,000 to 24,000 people)
Also
"Rancho Don Antonio and nearby Santa Matilde, a community with 7,000 households also in the process of being introduced to the HotZone"
Im not sure if the 7000 Households is each community or both? (But add another minimum of 17,500 to 21,000 people)
Mitch Siegel LOST on the March 20th hearing. He tried to get a final Default Judgement and it was "DENIED"
Maybe because Globetel, through Jonathan Leinwand filed answers to the Complaint a week earlier on March 13th.
Here is Part of Globetels Response from the March 13th filing.
26. Unclean hands. Siegel breached his contract with GTEL by not performing his duties as an officer and employee to the satisfaction of the company.
27. Accord and Satisfaction. Siegel received his full benefits with the company until Mr. Siegel brought a deal to GTEL wherein the Magic Money Division was sold to Gotham Financial, LLC of which Mr. Siegel has an equity ownership position. Gotham Financial, LLC assumed the assets of Magic Money on or about October 30, 2006
Signed by Jonathan D Leinwand
Makes me wonder how accurate your Palmdale "DD" is?
E*Trade Level 2 Showing all morning.
NITE Bid .24
NITE Ask .26
All 5 trades at .24
NITE just dropped to .23
It's already been announced.
The project went to Sacramento Metro Connect, LLC
It's actually Wells Fargo Financial Leasing Inc.
Not Wells Fargo. Big difference.
One Loans money the other loans office equipment such as copiers and fax machines.
Michael Decarlo vs. Globetel Civil Suit Dismissed.
06/07/07 25704 / 2290Pages:2 VOLUNTARY DISMISSAL
05/29/07 TEXT CIVIL COVER SHEET, ATTACHED EXHIBIT A FILED
05/25/07 CIVIL COVER
05/25/07 COMPLAINT
05/25/07 SUMMONS ISSUED DN01
"Voluntary dismissal is when a law suit is terminated by request of the plaintiff" (the party originally bringing the suit to court).
Sacramento Bid Update. Sacramento Metro Connect is going to be recommended to the City Council this Thursday.
Recommendation: Adopt a Resolution 1) approving the agreement for the Design, Deployment and Operation of Wireless Broadband Network in Sacramento between the City and Sacramento Metro Connect, LLC (SMC); 2) approving the Anchor Tenancy service agreement between the City and SMC for wireless broadband network services to City offices and employees; 3) directing staff to bring to Council for approval zoning code amendments and a revocable permit agreement for the installation and implementation of a citywide wireless broadband network. Contact: Stephen R. Ferguson, Chief Information Officer, (916) 808-8600, Dean Peckham, Senior Project Manager, (916) 808-7063, Thanh V. Vo, IT Project Manager, (916) 808-7988, Information Technology and Economic Development Departments
John Coniglio was the person Globetel worked with. He signed off on the revenue recognition in the days of Tim Jimenez. They helped compile the financials for reporting to the auditors. The time in which he worked for Globetel is within the range of times that needed re-examination.
Class action Lawsuit updated yesterday.
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
Case No. 06-21071-CIV-ALTONAGA/Turnoff
RICHARD STEVENS, et al., on behalf of
themselves and all others similarly situated,
Plaintiffs, v. GLOBETEL COMMUNICATIONS CORP., et al.,Defendants.
JOINT MOTION TO
SET MEDIATION SCHEDULE AND STAY PROCEEDINGS
Pursuant to the Court’s Order, dated May 10, 2007, Plaintiffs and Defendants jointly move to set a mediation schedule and stay all proceedings until September 10, 2007. In support of this motion, the parties state as follows:
1. On May 10, 2007, the Court issued an Order Setting Trial and Pre-trial Schedule, Requiring Mediation, and Referring Certain Motions to Magistrate Judge (the “Scheduling Order”);
2. The Scheduling Order directed the parties to select a mediator and a time and place for the mediation to take place, as well as to jointly file, by June 11, 2007, a proposed order scheduling mediation.
3. The parties have conferred regarding the Scheduling Order and have selected retired Judge Nicholas H. Politan as a mediator. The parties are presently coordinating among themselves, Judge Politan and counsel for Defendants’ insurance carrier, to schedule the mediation to occur in Case 1:06-cv-21071-CMA Document 68-1 Entered on FLSD Docket 1 Also participating in the mediation will be counsel for plaintiff in the currently stayed shareholder derivative action brought nominally on behalf of GlobeTel. See Stockton v.Dumas et al., 06-60923-CIV (stayed pursuant to Order On Joint Motion For An Order Staying Action, dated September 1, 2006 [Docket No. 15]). New York City between August 15, 2007 and August 31, 2007. The parties are hopeful that they will settle the case at mediation. Pursuant to the Scheduling Order, the parties will file a mediation report with the Court within five (5) days of the mediation.
4. In order to conserve resources and promote a resolution of this action by allowing the parties to focus their attention on the mediation, the parties request that this action be stayed until September 10, 2007, with all dates in the Scheduling Order tolled until that time.
WHEREFORE, the parties respectfully request that they mediate the claims asserted herein with Judge Politan and stay all proceedings until September 10, 2007. A proposed order reflecting the foregoing is submitted herewith.
Dated: June 11, 2007 Respectfully submitted,
VIANALE & VIANALE LLP
/s/ Julie P. Vianale
Kenneth Vianale (FBN 0169688)
Julie P. Vianale (FBN 0184977)
2499 Glades Road, Suite 112
Boca Raton, Florida 33431
Tel: 561-392-4750
Plaintiffs’ Liaison Counsel
SHALOV STONE BONNER & ROCCO LLP
Lee Shalov
Thomas G. Ciarlone, Jr.
485 Seventh Avenue, Suite 1000
New York, NY 10018
Tel: 212-239-4340
SARRAF GENTILE LLP
Ronen Sarraf
Joseph Gentile
485 Seventh Avenue, Suite 1005
New York, NY 10018
Tel: 212-868-3610
Plaintiffs’ Co-Lead Counsel
GUNSTER, YOAKLEY & STEWART, P.A.
/s/ John F. Mariani (w/ consent)
John F. Mariani (FBN: 263524)
Phillips Point - Suite 500 East
777 South Flagler Drive
West Palm Beach, FL 33401-6194
Tel: 561-650-0600
GOODWIN PROCTER LLP
Brian E. Pastuszenski
Alexis L. Shapiro
53 State Street Exchange Place
Boston, MA 02109
Tel: 617-570-1000
Counsel for Defendants GlobeTel
Communications Corp. and Timothy Huff
Area's Bold and underlined I added. WilliamFL
Globetel Defense to Mitchell Siegel Complaint.
Entered March 13, 2007
26. Unclean hands. Siegel breached his contract with GTEL by not performing his duties as an officer and employee to the satisfaction of the company.
27. Accord and Satisfaction. Siegel received his full benefits with the company until Mr. Siegel brought a deal to GTEL wherein the Magic Money Division was sold to Gotham Financial, LLC of which Mr. Siegel has an equity ownership position. Gotham Financial, LLC assumed the assets of Magic Money on or about October 30, 2006
Signed by Jonathan D Leinwand
Maybe? Obviously? Seem to contradict each other.
"Obviously, his elite staff failed to file the appropriate change of address documents"
LOL, IMO
Uh Vern? Do you happen to have Mr. Sarraf Manhatten Office Suite Address? The US District Court would like to deliver mail to him.
From the Court Docket entered last week:
Notice of Undeliverable Mail re58: Order Requiring Joint Scheduling Report US Mail returned for: Ronen Sarraf, Not at this address, Need updated address information (ww)(Entered: 04/26/2007)
"He is in the business of fighting for his clients tooth and nail"
LOL, IMO
Yea, I thought that was funny too :)
IMO
Just filed..
JOINT SCHEDULING REPORT
Pursuant to Federal Rules of Civil Procedure 26(f) and S.D. Fla. Local Rule 16.1.B, the
parties file this Joint Scheduling Report and proposed Scheduling Order.
I. INTRODUCTION
This is a shareholder class action alleging violations of Sections 10(b) and 20(a) of the
Securities Exchange Act of 1934. The operative complaint is the Corrected Consolidated Amended
Class Action Complaint (the “Complaint”) [D.E. No. 32], as amended by this Court’s Order dated
April 4, 2007, granting in part and denying in part the Defendants’ motion to dismiss [D.E. No. 57].
Plaintiffs chose to stand on the remaining allegations in the Complaint and did not amend. Pursuant
to this Court’s Order dated April 30, 2007, Defendants’ Answer is due on or before June 26, 2007
[D.E. No. 63].
On April 24, 2007, the parties conferred by telephone pursuant to Rule 26(f) and with regard
to this scheduling report and order. A proposed Scheduling Order is attached hereto as Exhibit A.
II. SCHEDULING REPORT
A. Initial Disclosures: The parties agree that they will exchange the information
required by Federal Rules of Civil Procedure 26(a) by May 8, 2007 (14 days following the parties’
Rule 26(f) conference).
B. Discovery Schedule: The parties believe that this case should be placed on the
Complex Track described in Local Rule 16.1.A.(2)(c). The parties agree that all fact discovery shall
be completed by 365 days after entry of the Court’s Scheduling Order. The parties further agree that:
1. Class Certification:
a. Plaintiffs shall serve their motion to certify the class within 60 days
after service of the Answer.
b. The parties shall complete all class discovery, and Defendants shall
serve their response to Plaintiffs’ class certification motion, within 60 days thereafter.
c. Any reply brief in support of class certification shall be served by
Plaintiffs within 30 days thereafter.
2. Fact Discovery: The service of interrogatories, requests for admission, and
requests for production consistent with Local Rule 26.1.G may commence immediately, and shall
be completed 275 days after entry of the Court’s Scheduling Order. Service of all such fact
discovery requests must be completed 30 days prior to the close of fact discovery. Apart from the
exceptions noted above and below, all discovery shall proceed in accordance with the Federal Rules
of Civil Procedure and the Local Rules of this Court (including General Appendix A thereto).
Defendants propose, and Plaintiffs agree, to limit the length of all depositions to seven (7) hours,
including breaks, except those depositions requiring the presence of an interpreter. The parties
reserve the right to seek modifications of this rule for specific deponents.
Case 1:06-cv-21071-CMA Document 64 Entered on FLSD Docket 05/03/2007 Page 2 of 5
3. Expert Discovery: Plaintiffs shall file their expert disclosures pursuant to
Federal Rules of Civil Procedure 26(a)(2)(A) and (B), within 30 days after the close of fact
discovery. Defendants’ expert disclosures pursuant to Federal Rules of Civil Procedure 26(a)(2)
shall be made within 60 days after the close of fact discovery. Plaintiffs shall file any rebuttal within
90 days of the close of fact discovery. The parties agree that they will produce their respective expert
witness(es) for deposition without requiring them to be formally subpoenaed, and that the parties
shall complete discovery concerning all experts, including their depositions, no later than the close
of discovery.
C. Settlement Discussion: The parties believe that settlement is possible and are
engaged in settlement talks.
D. Time to Join Other Parties or to Amend Pleadings: The parties request 90 days
from the time Defendants serve their Answer to join other parties and/or to amend the pleadings.
Defendants currently do not anticipate adding parties. Plaintiffs are currently unable to evaluate
whether additional parties will be joined.
E. Motions: The parties agree that the deadline for filing dispositive pretrial motions
and memoranda of law, including motions for summary judgment or partial summary judgment,
should be no later than 90 days after the close of all discovery. The parties further agree that the
party opposing a potentially dispositive motion shall have 45 days to serve a response in opposition
to such motion, and that the moving party shall have 45 days following any response in opposition
to serve a reply. The parties propose that the deadline for filing motions in limine and pretrial
motions other than dispositive motions should be 60 days prior to trial. Responsive briefs shall be
served no later than 30 days prior to trial and replies shall be served no later than 15 days prior to
trial.
Case 1:06-cv-21071-CMA Document 64 Entered on FLSD Docket 05/03/2007 Page 3 of 5
F. Stipulations and Avoidance of Unnecessary Proof: The parties will seek to obtain
admissions and stipulations on undisputed facts. The parties will also work together to stipulate to
authenticity and/or admissibility of documents and other evidence, or to narrow any objections to
authenticity or admissibility. The parties will meet to discuss the stipulation of facts and the
authentication of documents at least 10 days prior to trial.
G. Advisability of Referring to Magistrate: The parties do not consent at this time to
referring this matter for trial to a United States Magistrate.
H. Estimate Time Required for Trial: The parties estimate that 15 trial days will be
required for the trial of this matter.
I. Requested Dates for Pretrial Conference and Trial: The parties request that the
final pretrial conference be held two weeks before the trial date.
Dated: May 3, 2007
Case 1:06-cv-21071-CMA Document 64 Entered on FLSD Docket 05/03/2007 Page 4 of 5
Case 1:06-cv-21071-CMA Document 64 Entered on FLSD Docket 05/03/2007 Page 5 of 5
Risk, as long as you put "IMO" in front of any unfounded accusation, that makes your Post Ok?
In your Opinion how is it that some Hack lawyer "Got wind of a Bad SEC decision?
Both parties are attempting to Settle. From the Court filing on April 27, 2007.
"Given that the parties are attempting to settle this litigation, Defendants respectfully request that their time to Answer the Complaint be extended by 60 days,"
The extension was granted to allow for settlement discussions.
That's it... EOM
Globetels request for Extension Granted:
ORDER
This cause, having come before the Court on Defendants, Globetel Communications Corp. and Timothy Huff’s (“Defendants”) Unopposed Motion to Extend Time to Respond to Consolidated Amended Class Action Complaint (“the Motion for Extension of Time”), filed on April 27, 2007 [D.E. 62]. Upon review of the Motion for Extension of Time, the pertinent portions of the record,and being otherwise fully informed in the premises, it is hereby ORDERED AND ADJUDGED that Defendants’ Motion for Extension of Time [D.E. 62] is GRANTED. Defendants shall submit their answer to the Consolidated Amended Class Action Complaint on or before June 26, 2007. DONE AND ORDERED in Chambers at Miami, Florida this 30th day of April, 2007.
_________________________________
CECILIA M. ALTONAGA
UNITED STATES DISTRICT JUDGE
From the 8K
Additional Covenants.
Employees and Consultants. Within 30 days of the execution of the agreement, Altvater may extend an offer of employment to any of GlobeTel Wireless's former or current US-based employees without objection of GlobeTel.
This should be interesting..
UNOPPOSED MOTION TO EXTEND TIME TO RESPOND
TO THE CONSOLIDATED AMENDED CLASS ACTION COMPLAINT
(BOLD IS MINE)
Defendant GlobeTel Communications Corp. (“GlobeTel”) and Timothy Huff
(“Defendants”), through their undersigned counsel, and pursuant to Local Rule 7.1.A, move this Court to enlarge the time in which they may file their answer to the consolidated amended class action complaint (the “Complaint”), and state as good cause the following:
1.The parties are currently discussing the possibility of settling this litigation.
2. The Complaint in this action is more than 50 pages and 156 paragraphs long, many of those paragraphs containing multiple allegations. The allegations in this lengthy complaint concern not only the specific transaction at issue in this litigation, but also make assertions concerning numerous other historical GlobeTel transactions that require a response from GlobeTel. As such, preparation of the Answer to that Complaint will cause the Defendants to spend significant resources.
3. Given that the parties are attempting to settle this litigation, Defendants respectfully request that their time to Answer the Complaint be extended by 60 days, in order to conserve resources. Defendants’ Answer to the Complaint is currently due on April 27, 2007. Thus, Defendants respectfully request that this deadline be extended to June 26, 2007.
4. No other deadlines will be affected by such an extension. The parties will still file their Joint Scheduling Report on May 3, 2007 as previously ordered.
5. Plaintiffs do not oppose the relief requested in this motion. WHEREFORE, Defendants respectfully request that the Court enter an order extending the time permitted for Defendants to file their answer until June 26, 2007;
A proposed order is attached hereto for the Court’s convenience.
Dated: April 27, 2007
West Palm Beach, FL
Respectfully submitted,
s/John F. Mariani _____________
John F. Mariani (FBN: 263524)
jmariani@gunster.com
Gunster, Yoakley & Stewart, P.A.
Phillips Point - Suite 500 East
777 South Flagler Drive
West Palm Beach, FL 33401-6194
Telephone: (561) 650-0600
Facsimile: (561) 655-5677
Brian E. Pastuszenski
bpastuszenski@goodwinprocter.com
Alexis L. Shapiro
ashapiro@goodwinprocter.com
Goodwin Procter LLP
53 State Street
Boston, MA 02109
Telephone: (617) 570-1000
Facsimile: (617) 523-1231
Attorneys for Defendants GlobeTel
Communications Corp. and Timothy Huff
Case 1:06-cv-21071-CMA Document 62 Entered on FLSD Docket 04/27/2007 Page 2 of 4
UNOPPOSED MOTION TO EXTEND TIME TO RESPOND
TO THE CONSOLIDATED AMENDED CLASS ACTION COMPLAINT
Defendant GlobeTel Communications Corp. (“GlobeTel”) and Timothy Huff, through their
undersigned counsel, and pursuant to Local Rule 7.1.A, move this Court to enlarge by 9 days the
time in which they may file their answer to the consolidated amended class action complaint (the
“Complaint”), and state as good cause the following:
1. On April 4, 2007, this Court issued an order on Defendants’ motion to dismiss the
Complaint. In that order, the Court dismissed from this action all defendants, except Defendants
GlobeTel and Huff. The Court also gave Plaintiffs until April 27, 2007 to file an amended
complaint.
2. On April 17, 2007, Plaintiffs informed defense counsel that they do not plan to file a further amended complaint.
3. Defendants GlobeTel and Huff’s answer is thus due on April 18, 2007. Under the
circumstances, defendants respectfully request that this deadline be extended to April 27, 2007.
CASE NO. 06-CIV-21071-ALTONAGA\TURNOFF
4. No other deadlines will be affected by such an extension. The parties will still file
their Joint Scheduling Report on May 3, 2007 as previously ordered.
5. Plaintiffs do not oppose the relief requested in this motion.
WHEREFORE, Defendants respectfully request that the Court enter an order extending the
time permitted for Defendants to file their answer until April 27, 2007;
Dated: April 18, 2007
West Palm Beach, FL
Respectfully submitted,
s/John F. Mariani _____________
John F. Mariani (FBN: 263524)
jmariani@gunster.com
Gunster, Yoakley & Stewart, P.A.
Phillips Point - Suite 500 East
777 South Flagler Drive
West Palm Beach, FL 33401-6194
Telephone: (561) 650-0600
Facsimile: (561) 655-5677
Brian E. Pastuszenski
bpastuszenski@goodwinprocter.com
Alexis L. Shapiro
ashapiro@goodwinprocter.com
Goodwin Procter LLP
53 State Street
Boston, MA 02109
Telephone: (617) 570-1000
Facsimile: (617) 523-1231
Attorneys for Defendants (GlobeTel
Communications Corp. and Timothy Huff)
Case 1:06-cv-21071-CMA Document 60-1 Entered on FLSD Docket 04/18/2007 Page 2 of 4
CASE NO. 06-CIV-21071-ALTONAGA\TURNOFF
CERTIFICATE OF SERVICE
I hereby certify that on April 18, 2007, I electronically filed the foregoing document with
the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
this day on all counsel of record or pro se parties identified on the attached Service List in the
manner specified, either via transmission of Notices of Electronic filing generated by CM/ECF
or in some other authorized manner for those counsel or parties who are not authorized to receive
electronically Notices of Electronic Filing.
s/John F. Mariani_______________
John F. Mariani
Case 1:06-cv-21071-CMA Document 60-1 Entered on FLSD Docket 04/18/2007 Page 3 of 4