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)

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: [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: November 14, 2011

Dated: November 14, 2011

4817-5232-4366, v. 1

2