Blaszkowski et al v. Mars Inc. et al

Filing 16

MOTION for Extension of Time to File Response as to 1 Complaint by Petco Animal Supplies, Inc.. (Bohrer, Sanford)

Blaszkowski et al v. Mars Inc. et al

Doc. 16

Case 1:07-cv-21221-CMA

Document 16

Entered on FLSD Docket 05/24/2007

Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION Case No. 07-21221 Civ-Altonaga/Turnoff RENEE BLASZKOWSKI, AMY HOLLUB and PATRICIA DAVIS, Individually and on behalf of others similarly situated, Plaintiffs, vs. MARS INC., PROCTOR AND GAMBLE CO., COLGATE PALMOLIVE COMPANY, DEL MONTE FOODS, CO., NESTLE U.S.A. INC., NUTRO PRODUCTS INC., MENU FOODS, INC., MENU FOODS INCOME FUND, PUBLIX SUPERMARKETS, INC., WINN DIXIE STORES, INC., PETCO ANIMAL SUPPLIES, INC., PET SUPERMARKET, INC., PETSMART INC., TARGET CORP., WAL-MART STORES, INC., Defendants. ___________________________________________/ MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT Defendant PETCO ANIMAL SUPPLIES, INC. ("PETCO") pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, moves for an extension of time up to and including July 5, 2007 to serve its response to the Complaint. The grounds for this motion are:

Dockets.Justia.com

Case 1:07-cv-21221-CMA

Document 16

Entered on FLSD Docket 05/24/2007

Page 2 of 4

1. Undersigned counsel was just recently hired to represent PETCO in this action. 2. PETCO and its counsel need the additional time to prepare a response to the Complaint. For example, PETCO's counsel has a three week jury trial beginning June 11, 2007. 3. This motion is made in good faith and not for any purpose of undue delay. 4. Pursuant to Local Rule 7.1(3a), counsel for PETCO has conferred with counsel for Plaintiffs and Plaintiffs' counsel could only agree to a two week extension of time, until June 19, 2007. WHEREFORE, Defendant Petco Animal Supplies, Inc. requests an extension of time, up to and including July 5, 2007 to serve its response to the Class Action Complaint. HOLLAND & KNIGHT LLP s/ Sanford L. Bohrer________________ Sanford L. Bohrer (FBN 160643) Scott D. Ponce (FBN 0169528) 701 Brickell Avenue, Suite 3000 Miami, FL 33131 Tel: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail]

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Case 1:07-cv-21221-CMA

Document 16

Entered on FLSD Docket 05/24/2007

Page 3 of 4

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24th day of May 2007, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notice of Electronic Filing.

s/Sanford L. Bohrer__________

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Case 1:07-cv-21221-CMA

Document 16

Entered on FLSD Docket 05/24/2007

Page 4 of 4

SERVICE LIST Blaszkowski, etc. vs. Mars, etc. Case No. 07-21221-Civ-Altonaga/Turnoff United States District Court, Southern District of Florida Catherine J. MacIvor Email: [e-mail] Maltzman Foreman, P.A. One Biscayne Tower 2 South Biscayne Blvd. Suite 2300 Miami, Florida 33131 Tel: [phone] Fax: [phone] Attorneys for Plaintiffs Service by: CM/ECF

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