Kotis et al v. Deslin Hotels, Inc. et al

Filing 17

First MOTION for Extension of Time to File Response/Reply to Plaintiffs' Complaint by Deslin Hotels, Inc.. (Weston, Kathryn) Motions referred to Magistrate Judge Elizabeth A. Jenkins.

Kotis et al v. Deslin Hotels, Inc. et al

Doc. 17

Case 8:07-cv-00447-JSM-EAJ

Document 17

Filed 05/22/2007

Page 1 of 3

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

HEATHER MARIE KOTIS and RACHEL CHRISTINE MILL, each individually, Plaintiffs, v. DESLIN HOTELS, INC., et al.

CASE NO.: 8:07cv00447-JSM-EAJ

Defendants. _________________________________________________/ DEFENDANT, DESLIN HOTELS, INC.'S, MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO PLAINTIFFS' COMPLAINT Defendant, DESLIN HOTELS, INC., by and through its undersigned attorneys, hereby moves this Court for an enlargement of time to file its responses to Plaintiffs' Complaint until June 7, 2007. Memorandum of Law Absent an enlargement of time, defendant DESLIN HOTELS, INC.'s is required to respond to the Complaint by May 23, 2007. The Complaint is extensive, with numerous defendants and several causes of action. Due to other demands on counsel's time, an extension of time is necessary to prepare and serve a response to the Complaint. Defendants, Deslin Hotels, Inc., Irene Devlin, and Dennis Devlin, will serve their response to the complaint on or before June 7, 2007. Local Rule 3.01(g) Certificate Counsel for the defendant certifies that prior to filing this motion, she has conferred with counsel for plaintiffs in a good faith effort to resolve the issues raised by this motion and plaintiffs' counsel does not oppose such enlargement of time to serve a responsive pleading to the Complaint.
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Dockets.Justia.com

Case 8:07-cv-00447-JSM-EAJ

Document 17

Filed 05/22/2007

Page 2 of 3

WHEREFORE, defendant, Deslin Hotels, Inc., respectfully requests this Court enter an order extending the deadline to serve a responsive pleading to the Complaint until June 7, 2007. Respectfully submitted,

COBB & COLE

By:

s/ Kathryn D. Weston KATHRYN D. WESTON FLA. BAR NO. 0897701 150 Magnolia Avenue Post Office Box 2491 Daytona Beach, FL 32115-2491 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] ATTORNEYS FOR DESLIN HOTELS, INC. IRENE DEVLIN, and DENNIS DEVLIN

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 22nd day of May, 2007, I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to the following Service List. s/Kathryn D. Weston Attorney Heather Marie Kotis Rachel Christine Mill Richard Stuart Shankman Litigation Concepts, L.C. 2536 NW 53rd Street Boca Raton, FL 33496 813-225-1818 Fax [phone] [e-mail]

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Case 8:07-cv-00447-JSM-EAJ

Document 17

Filed 05/22/2007

Page 3 of 3

Stanford R. Solomon Mark Stephen Howard The Solomon Tropp Law Group 1881 West Kennedy Boulevard Tampa, FL 33606-1643 813-225-1818 Fax [phone] [e-mail] [e-mail] Thomas E. DeBerg The Solomon Tropp Law Group 1881 West Kennedy Boulevard Tampa, FL 33606-1643 813-225-1818 Fax [phone] [e-mail] BV&BK Productions LLP Chad W. Ciani Camille Godwin Cohen, Jayson & Foster, P.A. 201 E. Kennedy Boulevard, Suite 1000 Tampa, FL 33602 [e-mail]

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