Stockwire Research Group, Inc. et al v. Lebed et al

Filing 21

Defendant's MOTION for Extension of Time to File Joint Scheduling Order by Pigasa, Inc., Constance Lebed, Jonathan Lebed, Lebed Biz, L.L.C.. (Attachments: # 1 Text of Proposed Order)(Cruz, Amaury)

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United States District Court Southern District of Florida Case No.: 07-22670 CIV-SEITZ/MCALILEY Stockwire Research Group, Inc., a Florida corporation, and ADRIAN JAMES, a Texas resident, Plaintiffs, vs. Jonathan Lebed, a Florida resident, Lebed Biz, L.L.C., a New Jersey Limited Liability Company, PIGASA, INC., a New Jersey corporation, and Constance Lebed, a New Jersey resident, Defendants. ____________________________________/ DEFENDANTS' NOTICE OF STRIKING DOCKET ENTRIES 14, 15 AND 16 Defendants, by and through undersigned counsel hereby files this Notice of Striking Docket Entries 14, 15 and 16 and in support states as follows: 1. On December 13, 2007, Defendants e-filed their Defendant Constance Lebed's Motion to Dismiss for Lack of Personal Jurisdiction (Docket Entry 14) and two supporting declarations (Docket Entries 15 and 16). In doing so, there was an error wherein the two declarations' title did not match their selected event. 2. Defendants e-filed this pleading a second time under Docket Entry 18. WHEREFORE, Defendants, by and through their undersigned counsel, request this Court to strike Docket Entries 14, 15, and 16 as moot. 1 Respectfully submitted, Christopher J. Van Dam, P.A. 12121 NE 16th Ave North Miami, FL 33161 Attorneys for the Defendants Voice: 305.446.5200 Fax: 866.233.2983 amaurycruz@yahoo.com By: __/s Amaury Cruz________ AMAURY CRUZ, ESQ. Fla. Bar No. 898244 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on December 14, 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 in 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 Notices of Electronic Filing. s/ Amaury Cruz, Esq. 2 SERVICE LIST CASE NO: 07-22670 CIV-SEITZ/MCALILEY Peter A. Koziol, Esq. pak@assoulineberlowe.com Assouline & Berlowe, P.A. 213 East Sheridan Street, Suite 3, Dania Beach, FL 33004 Telephone: 954.929.1899 Facsimile: 954.922.6662 Attorneys for Plaintiffs STOCKWIRE RESEARCH GROUP, INC. and ADRIAN JAMES 3

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