Rice et al v. Lucky Brand Dungarees Stores, Inc.

Filing 6

Joint MOTION for Extension of Time to File Answer RE: Complaints re 1 Complaint, by Lucky Brand Dungarees Stores, Inc.. (Attachments: # 1 Text of Proposed Order Granting Joint Motion for Extension)(Norfus, Natalie)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
FT. LAUDERDALE DIVISION
CASE NO.: 11-cv-61923-WPD
LORILYNN RICE, KRISTEN
GURDAK, GABRIEL AGUILAR,
BRITTANY SOTO, and LAUREN
TAYLOR, on their own behavior
and other similarly situated,
Plaintiff,
vs.
LUCKY BRAND DUNGAREES
STORES, INC., a Foreign Profit
Corporation,
Defendant,
/
JOINT MOTION FOR EXTENSION OF TIME IN WHICH
FOR DEFENDANT TO FILE AN ANSWER OR OTHER
RESPONSIVE PLEADING TO PLAINTIFFS’ COMPLAINT
Plaintiffs Lorilynn Rice, Kristen Gurdak, Gabriel Aguilar, Brittany Soto, and Lauren
Taylor (“Plaintiffs”) and Defendant Lucky Brand Dungarees Stores, Inc. (“Defendant”)
(collectively, the “Parties”) respectfully requests this Court to extend the deadline by which
Defendant must file its Answer or other responsive pleading to Plaintiffs’ Complaint by 30 days
or until November 14, 2011. As grounds for this Motion the Parties state:
1.

Plaintiffs filed their Complaint in this action on August 30, 2011. D.E. 1.

2.

Defendant’s responsive pleading to Plaintiff’s Complaint is due on or about

October 13, 2011.
3.

The Parties have been engaged in productive conversations in an attempt to

resolve the issues raised in Plaintiffs’ Complaint. The Parties are, therefore, hopeful that the

issues raised in Plaintiffs’ Complaint will be completely resolved short of Court involvement or,
at a minimum, significantly narrowed.
4.

The Parties submit that no party will be prejudiced by this extension and it is not

being requested for an improper purpose.
5.

Accordingly, the Parties jointly request that the Court extend Defendant’s time for

responding to Plaintiffs’ Complaint by 30 days or until November 14, 2011.

By: s/Kelly Amritt
Kelly Amritt, Esq.
Florida Bar No. 0648779
Email: [e-mail]
Law Offices of Robert Rubenstein, P.A.
2 South University Drive, Suite 235
Plantation, Florida 33324
Telephone: [phone]
Facsimile: 954-515-5787

By: Natalie E. Norfus
Natalie E. Norfus, Esq.
Florida Bar No.: 70109
Email: [e-mail]
Jackson Lewis, LLP
One Biscayne Tower
2 South Biscayne Boulevard, Suite 3500
Miami, Florida 33131
Telephone: [phone]
Facsimile: 305-373-4466

Dated: October 13, 2011

Dated: October 13, 2011

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