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
