Silvers v. Google, Inc.

Filing 185

RESPONSE TO ORDER TO SHOW CAUSE by Steven A. Silvers. (Cooper, Robert)

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Silvers v. Google, Inc. Doc. 185 Case 9:05-cv-80387-KLR Document 185 Entered on FLSD Docket 11/09/2006 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CIVIL DIVISION CASE NO. 05-80387-CIV-RYSKAMP/VITUNAC Stephen A. v. Google Inc., a Delaware corporation Defendant Silvers, an individual Plaintiff ______________________________________ Silvers' Response to Order to Show Cause and Incorporated Second Motion for Extension of Time to Respond to Stelor's Motion for Summary Judgment Silvers responds to this Court's Order to Show Cause and moves this Honorable Court for a second motion for extension of time to respond to Stelor's Motion for Summary and states: 1. Today, this Court entered an Order to Show Cause (Doc. 184) based upon Silver's perceived failure to timely respond to Stelor's Motion for Summary Judgment (Doc. 140). 2. This Court however granted Silvers an extension until Nov. 10, 2006 to respond to Stelor's motion for summary judgment in its Order dated October 25, 2006 (Doc. 157). 3. The undersigned counsel filed its appearance in this action 1 Dockets.Justia.com Case 9:05-cv-80387-KLR Document 185 Entered on FLSD Docket 11/09/2006 Page 2 of 3 for Silvers for the first time on 11/1/06 only 5 working days ago. 4. This is a very complicated matter and the undersigned counsel has been diligently trying to learn the facts and history of this case and prepare a response to Stelor's Motion for Summary Judgment. 5. In addition, the undersigned counsel has also been engaged in ongoing settlement discussions with Stelor to make a good faith attempt to resolve the issues between Stelor and Silvers which efforts have also slowed the undersigned counsel's progress in learning the facts and history of this case and preparing a response to Stelor's Motion for Summary Judgment. 6. The undersigned counsel respectfully requests an additional 10 days to respond to Stelor's motion for Summary Judgment. 7. Stelor's counsel represented he is not authorized by his client to agree to the extension. Robert H. Cooper P.A. 2 Case 9:05-cv-80387-KLR Document 185 Entered on FLSD Docket 11/09/2006 Page 3 of 3 2999 N.E. 191 St. Suite 704 Miami, Fl. 33180 305-792-4343 (direct extension) 305-792-0200 (fax) robert@rcooperpa.com Fl. Bar No. 0650323 s/ Robert H. Cooper Robert H. Cooper for the Firm. 3

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