Blaszkowski et al v. Mars Inc. et al

Filing 131

Notice of Instruction to Filer Regarding Pro Hac Vice Motion. Pursuant to 2B in the Administrative Procedures, a motion to make a limited appearance must be filed in the conventional manner along with the applicable filing fee. LOCAL COUNSEL IS INSTRUCTED TO 1. FILE A NOTICE TO STRIKE DE# 121 MOTION for Leave to Appear Consent to Designation and Request to Electronically Receive Notices of Electronic Filings Pro Hac Vice filed by Petsmart Inc., AND 2. CONVENTIONALLY FILE AN ORIGINAL MOTION TO MAKE A LIMITED APPEARANCE ALONG WITH THE APPLICABLE FILING FEE. (cw)

Blaszkowski et al v. Mars Inc. et al

Doc. 131

Case 1:07-cv-21221-CMA Document 1

Entered on FLSD Docket 05/10/2007 Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 07-80603-CIV-HURLEY/HOPKINS TARA LOCASTRO, on her own behalf and all others similarly situated, Plaintiff, v. LYDIAN TRUST COMPANY, a Florida corporation, Defendant. ________________________________/ DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME The defendant, Lydian Trust Company ("Lydian"), moves for two-week enlargement of time within which to serve its responses to Plaintiff's Requests for Admissions, Interrogatories and Request for Production, and in support states as follows: 1. Locastro served discovery requests on Lydian, including Requests for August 30, 2007. Lydian's

Admissions, Interrogatories and a Request for Production on responses are currently due October 2, 2007. 2.

Due to the press of other matters, Lydian requires a brief enlargement of time to

respond to Plaintiff's discovery requests. 3. purposes. 4. Counsel for Lydian has conferred with Plaintiff's counsel, regarding the subject Plaintiff's counsel has advised Counsel for Lydian that he has no This enlargement is sought in good faith and not for dilatory or improper

matter of this motion.

objection to providing Lydian with the requested two-week enlargement.

Dockets.Justia.com

Case 1:07-cv-21221-CMA Document 1

Entered on FLSD Docket 05/10/2007 Page 2 of 4

5.

Lydian's request for an enlargement of time should be granted pursuant to Rule

6(b) of the Federal Rules of Civil Procedure, which provides in part: "[w]hen by these rules . . . an act is required or allowed to be done at or within a specified time, the court for cause shown may at any time in its discretion . . . order the period enlarged if request therefore is made before the expiration of the period originally prescribed . . ." FED.R.CIV.P. 6(b). 6. For the foregoing reasons, Lydian respectfully requests the entry of an Order

granting it a two-week enlargement of time within which to serve its responses to Plaintiff's discovery requests. Date: October 2, 2007 FISHER & PHILLIPS LLP 450 East Las Olas Boulevard Suite 800 Fort Lauderdale, Florida 33301 Telephone: [phone] Facsimile: [phone] Respectfully submitted, By: /s/ David A. Buchsbaum Cathy M. Stutin (Fla. Bar No. 865011) [e-mail] David A. Buchsbaum (Fla. Bar No. 117961) [e-mail] Attorneys for Defendant

Case 1:07-cv-21221-CMA Document 1

Entered on FLSD Docket 05/10/2007 Page 3 of 4

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME was served by CM/ECF and by depositing same in the United States Mail, First Class, postage prepaid on October 2, 2007 on all counsel or parties of record on the attached service list. /s/ David A. Buchsbaum Cathy M. Stutin (Fla. Bar No. 865011) [e-mail] David A. Buchsbaum (Fla. Bar No. 117961) [e-mail] FISHER & PHILLIPS LLP 450 E. Las Olas Boulevard Suite 800 Fort Lauderdale, Florida 33301 Telephone [phone] Facsimile [phone] Attorneys for Defendant

Case 1:07-cv-21221-CMA Document 1

Entered on FLSD Docket 05/10/2007 Page 4 of 4

SERVICE LIST CASE NO. 07-80603-CIV-HURLEY/HOPKINS Charles L. Pickett (Fla. Bar No. 0051217) [e-mail] Casey Ciklin Lubitz Martens & O'Connell 515 N. Flagler Drive, Suite 1900 West Palm Beach, Florida 33401-4343 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Cathy M. Stutin (Fla. Bar No. 865011) [e-mail] David A. Buchsbaum (Fla. Bar No. 117961) [e-mail] Fisher & Phillips LLP 450 East Las Olas Boulevard, Suite 800 Fort Lauderdale, Florida 33301 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants