Segal et al v. Amazon.com, Inc.

Filing 15

Unopposed MOTION for Extension of Time to File Answer RE: Complaints re 1 Complaint by Amazon.com, Inc.. (Attachments: # 1 Text of Proposed Order)(Esau, David)

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO. 10-CIV-20718-COOKE/BANDSTRA ALBERT SEGAL, and MARIANNA CHAPAROVA, - vs. Plaintiffs,

AMAZON.COM, INC., Defendant. ______________________________/ DEFENDANT AMAZON.COM, INC.'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO THE COMPLAINT Pursuant to Southern District of Florida Local Rule 7.1.A.3, Defendant Amazon.com, Inc. ("Amazon") hereby files its Unopposed Motion for Extension of Time to Respond to the Complaint, and in support thereof states as follows: 1. [D.E. 1]. On or about March 10, 2010, Plaintiffs filed their original Complaint in this Court Defendant Amazon waived service of process, and Amazon's response to the

Complaint is due on or before May 10, 2010 [D.E. 5]. 2. Undersigned counsel for Amazon was recently retained in this matter, and has not

yet had an opportunity to adequately investigate the claims and allegations raised in the Complaint. Additionally, the parties are currently exploring settlement options. 3. For these reasons, Amazon seeks a short one-week enlargement of time up to and

including May 17, 2010 to file its response to the Complaint. 4. Plaintiffs have indicated that they have no opposition to extending the time for

Amazon to respond to the Complaint up through and including May 17, 2010.

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5.

This request for extension is reasonable under the circumstances, is not sought for

the purpose of delay, and will not prejudice any party. WHEREFORE, Defendant Amazon respectfully requests the Court to enter an Order granting an extension of time for Amazon to respond to the Complaint up through and including May 17, 2010. LOCAL RULE 7.1(A)(3) CERTIFICATION Pursuant to Local Rule 7.1(A)(3), undersigned counsel for Amazon certifies that he has conferred with Plaintiffs in a good faith effort to resolve the issues raised in this motion, and that Plaintiffs have indicated that they do not oppose the relief requested. D ated: May 7, 2010 CARLTON FIELDS, P.A. CityPlace Tower ­ Suite 1200 525 Okeechobee Boulevard West Palm Beach, Florida 33401 Telephone: [phone] Facsimile: [phone]

By: /s/ David B. Esau James B. Baldinger Florida Bar No.: 869899 [e-mail] David B. Esau Florida Bar No.: 650331 [e-mail] Counsel for Defendant Amazon.com, Inc.

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CERTIFICATE OF SERVICE I hereby certify that on May 7, 2010, 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 identified on the 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 system: /s/ David B. Esau David B. Esau SERVICE LIST Albert Segal 10490 S.W. 12th Terr. Apt# 202 Miami, Fl 33174 (via U.S. Mail) Marianna Chaparova 10490 S.W. 12th Terr. Apt# 202 Miami, Fl 33174 (via U.S. Mail)

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