Whitney Information, et al v. Xcentric Ventures, et al

Filing 128

Joint MOTION for Extension of Time to File Response/Reply as to 119 MOTION for Extension of Time to File Response/Reply as to 115 MOTION for summary judgment pursuant to Rule 56(f) MOTION for Extension of Time to File Response/Reply as to 115 MOTION for summary judgment pursuant to Rule 56(f), 124 MOTION to compel Sworn Answers to Second and Third Sets of Interrogatories, Better Answers to Second Set of Interrogatories and Second Request for Production, Supplement to Motion for Extension of Time to Respond to Motion for Summary Judgment and, 125 Amended MOTION to compel Documents Responsive to First Request for Production and Additional Supplement to Motion for Extension of Time to Respond to Motion for Summary Judgment by all defendants. (Speth, Maria)

Whitney Information, et al v. Xcentric Ventures, et al

Doc. 128

Case 2:04-cv-00047-MMH-SPC

Document 128

Filed 07/18/2007

Page 1 of 3

Maria Crimi Speth, #012574 (Admitted Pro Hac Vice) JABURG & WILK, P.C. 3200 North Central Avenue, Suite 2000 Phoenix, Arizona 85012 [phone] Attorneys for Defendants

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA

WHITNEY INFORMATION NETWORK, INC.; a Colorado corporation, Plaintiffs, v. XCENTRIC VENTURES, LLC, an Arizona limited liability company; BADBUSINESSBUREAU.ORG, an Arizona limited liability company; and ED MAGEDSON, an individual, Defendants.

Case No: 2:04-CV-47-ftm-34-SPC STIPULATED MOTION TO EXTEND TIME TO RESPONDE TO PLAINTIFFS MOTIONS PURSUANT TO RULE 56 (f) AND MOTIONS TO COMPEL

Plaintiff Whitney Information Network and Defendants Xcentric Ventures, LLC, ("Xcentric"), and Ed Magedson ("Magedson") (collectively, the "Defendants") move the Court to extend time to respond to three pending motions until July 25, 2007. The parties have agreed to allow extension of time for response because of mutual efforts to reach agreement about discovery disputes and possible resolution of the case. The parties stipulate to the additional time to respond to three specific motions: Motion for Additional Discovery Time Pursuant to Rule 56(f), FRCP to Respond to Defendants' Motion for Summary Judgment and Incorporated Memorandum of Law, response due July 18, 2007; Plaintiff's Motion to Compel Sworn Answers to Second and Third Sets of Interrogatories, Better Answers to Second Set of Interrogatories and Second Request for Production, Supplement to Motion for Extension of Time to Respond to Motion for Summary Judgment and Incorporated
10297-8/ASK/ASK/599687_v1

Dockets.Justia.com

Case 2:04-cv-00047-MMH-SPC

Document 128

Filed 07/18/2007

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Memorandum of Law, response due July 20; and Plaintiff's Renewed Amended Motion to Compel Documents Responsive to First Request for Production, Additional Supplement to Motion for Extension of Time to Respond to Motion for Summary Judgment and Incorporated Memorandum of Law, response due July 23. For the reasons stated including agreement of the parties, Defendants request that the time to respond to the three motions be extended to July 25, 2007.

DATED this 18th day of July, 2007.

ROTHSTEIN ROSENFELD ADLER /s/ Shawn L. Birken Shawn L. Birken Attorneys for Plaintiff

JABURG & WILK, P.C.

s/Maria Crimi Speth Maria Crimi Speth, Esq. Attorneys for Defendants

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Case 2:04-cv-00047-MMH-SPC

Document 128

Filed 07/18/2007

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CERTIFICATE OF SERVICE I hereby certify that on the 18th day of July, 2007, I caused the attached document to be electronically transmitted to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF Registrants: Steven Neil Lippman Shawn L. Birken Scott W. Rothstein Rothstein Rosenfeld Adler Suite 1650 401 E Las Olas Blvd Ft Lauderdale, FL 33301 Attorneys for Plaintiff Brian J. Stack Stack, Fernandez, Anderson, Harris & Wallace, P.A. 1200 Brickell Ave., Suite 950 Miami, FL 33131-3255 Co-Counsel for Defendants

s/ L. Matlack

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