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

Filing 8

Joint MOTION for Extension of Time to File Answer RE: Complaints re 1 Complaint, by Gabriel Aguilar, Kristen Gurdak, Lucky Brand Dungarees Stores, Inc., Lorilynn Rice, Brittany Soto, Lauren Taylor. (Attachments: # 1 Text of Proposed Order Granting Joint Motion for Extension)(Norfus, Natalie)

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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 two week or until November 28, 2011. As grounds for this Motion the Parties state: 1. Plaintiffs filed their Complaint in this action on August 30, 2011 [D.E. 1]. Defendant’s responsive pleading to Plaintiff’s Complaint was due on or about October 13, 2011. 2. On October 13, 2011, parties jointly file a Motion for Extension of Time [D.E. 6]. 3. This Court entered an Order Granting Joint Motion for Extension of Time to File Response [D.E. 7]. Defendant’s responsive pleading is due on November 14, 2011. 4. Since the time the Parties filed their first Joint Motion, they have been engaged in fruitful settlement discussions. Indeed, the parties are close to reaching an agreement to resolve Plaintiffs’ complaint that will require little or no Court involvement. The Parties need, however, additional time to work out all of the details. 5. The Parties submit that no party will be prejudiced by this extension and it is not being requested for an improper purpose. 6. Accordingly, the Parties jointly request that the Court extend Defendant’s time for responding to Plaintiffs’ Complaint by two week or until November 28, 2011. By: s/Kelly Amritt Kelly Amritt, Esq. Florida Bar No. 0648779 Email: kelly@robertrubenstein.com Law Offices of Robert Rubenstein, P.A. 2 South University Drive, Suite 235 Plantation, Florida 33324 Telephone: 954-661-6000 Facsimile: 954-515-5787 By: Natalie E. Norfus Natalie E. Norfus, Esq. Florida Bar No.: 70109 Email: natalie.norfus@jacksonlewis.com Jackson Lewis, LLP One Biscayne Tower 2 South Biscayne Boulevard, Suite 3500 Miami, Florida 33131 Telephone: 305-577-7600 Facsimile: 305-373-4466 Dated: November 14, 2011 Dated: November 14, 2011 4817-5232-4366, v. 1 2

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