Plastic2Oil Inc (PTOI)

[scion]

12/08/2010 20 Unopposed MOTION to extend time to Respond to Plaintiff's Response to Defendants' Motion to Dismiss and Cross Motion for Leave to Conduct Discovery on Personal Jurisdiction and for Leave to Amend Complaint by John Bordynuik, JBI, Inc.. (Beveridge, Cathy) (Entered: 12/08/2010)

Doc 20 PDF file
http://viewer.zoho.com/docs/mFdFF

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION TO DISMISS AND CROSS MOTION FOR LEAVE TO CONDUCT DISCOVERY ON PERSONAL JURISDICTION AND FOR LEAVE TO AMEND COMPLAINT

Defendants, JBI, INC. and JOHN BORDYNUIK, by and through their undersigned counsel, and pursuant to Fed. R. Civ. P. 6(b) and Local Rule 3.01 file their unopposed motion for extension of time to respond to Plaintiffs Response to Defendants' Motion to Dismiss and Cross Motion for Leave to conduct Discovery on Personal Jurisdiction and for Leave to Amend Complaint in this case and state:

1. On November 23, 2010, Plaintiff filed his Response to Defendants' Motion to Dismiss and Cross Motion for Leave to Conduct Discovery on Personal Jurisdiction and for Leave to Amend the Complaint ("Plaintiffs Motion").

2. Under the applicable rules, the deadline to respond to Plaintiffs Motion is December 10,2010.

3. Counsel for the Defendants has not had sufficient time to analyze the facts and issues addressed in Plaintiff s Motion and prepare and file an appropriate response.

4. Accordingly, the Defendants respectfully request up to and including December 17, 2010 to serve responsive pleadings or take other appropriate action.

5. The undersigned attorney certifies that this Motion is filed in good faith and not for purposes of delay.

6. Defendants' counsel conferred with Plaintiffs counsel concerning this extension on December 7,2010. Undersigned counsel represents that Plaintiffs counsel does not oppose the extension requested in this Motion.

WHEREFORE, Defendants, JBI, INC. and JOHN BORDYNUIK, respectfully request that the Court enter an Order granting them up to and including December 17, 2010 to serve their responses to Plaintiffs Response to Defendants' Motion to Dismiss and Cross Motion for Leave to conduct Discovery on Personal Jurisdiction and for Leave to Amend Complaint.

DATED: December 8, 2010

/s/ Cathy J. Beveridge
Cathy J. Beveridge
Florida Bar No.: 0831018
FOWLER WHITE BOGGS P.A.
501 E. Kennedy Boulevard, Suite 1700
Tampa, Florida 33602-5239
[phone]/Facsimile: [phone]
[e-mail]
Counsel for Defendants