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)
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 (813) 228-7411/Facsimile: (813) 229-8313 cbeveridge@fowlerwhite.com Counsel for Defendants
Pacer update 09 Dec 10 Kaplanis v. JBI, Inc. et al CIVIL DOCKET FOR CASE #: 8:10-cv-02140-EAK-AEP
Date Filed # Docket Text
12/09/2010 21 ENDORSED ORDER granting 20 Motion to extend time to respond to pending motion up to and including 12/17/10. Signed by Judge Elizabeth A. Kovachevich on 12/9/2010. (SN) (Entered: 12/09/2010)
Kaplanis v. JBI, Inc. et al
Assigned to: Judge Elizabeth A. Kovachevich Referred to: Magistrate Judge Anthony E. Porcelli
Cause: 28:1332 Diversity-Breach of Contract
Date Filed: 09/27/2010 Jury Demand: Plaintiff Nature of Suit: 190 Contract: Other Jurisdiction: Diversity
Plaintiff Michael Kaplanis
represented by Jonathan T. Gilbert Feldman, Fox & Morgado, PA Suite 1000 2701 N Rocky Point Dr Tampa, FL 33607 813/639/9366 Fax: 813/639/9376 Email: jgilbert@ffmlawgroup.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
V.
Defendant JBI, Inc. a Nevada Corporation
represented by Cathy J. Beveridge Fowler White Boggs 501 E Kennedy Blvd - Ste 1700 (33602) PO Box 1438 Tampa, FL 33601-1438 813/228-7411 ext: 1145 Fax: 813/229-8313 Email: cbeveridge@fowlerwhite.com LEAD ATTORNEY ATTORNEY TO BE NOTICED
Defendant John Bordynuik an individual
represented by Cathy J. Beveridge (See above for address) LEAD ATTORNEY ATTORNEY TO BE NOTICED
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