Music Licensing Inc (SONG)

[lucky, mydog]

PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
TO EFFECTUATE SERVICE OF PROCESS ON DEFENDANTS
Plaintiffs, by and through undersigned counsel, move for entry of an Order granting an
extension of time to Effectuate Service of Process on Defendants. In support thereof, Plaintiffs
state the following:
1. Plaintiff’s counsel are in the process of domesticating three subpoenas to three
corporate entities in California.
2. Because the entities are California entities, all three entities’ counsel requested
Plaintiffs’ counsel to domesticate the subpoenas in California per the California
Discovery Act and California Code of Civil Procedure §§ 2029.300 and 2029.350.
3. This processing time for California subpoenas to be domesticated and issued takes
about 45 days.
4. Once issued, we will have to reserve the California entities then wait to receive their
requested records.
5. Due to the unknown identity of the defendants, upon receipt of the entities’ records,
further skip tracing may be necessary to then attain new summons to serve those
individuals.
Filing # 203229474 E-Filed 07/24/2024 11:54:38 AM
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/24/2024 11:54:38 AM
6. For the reasons above, Plaintiffs’ counsel requires extended time to locate and serve
defendants.
Plaintiffs respectfully request that the initial service deadline of August 16, 2024, may be
extended as follows:
Original
Deadline
Extended Deadline
Deadline For Effectuate
Service of Process on
Defendants:
08/16/2024 12/14/2024
7. This motion is done in good faith and not intended to cause delays and is not prejudicial
to any parties.
WHEREFORE, Plaintiffs move for entry of an Order granting an extension of time to
Effectuate Service of Process on Defendants
and all other relief this court deems just and
appropriate.