Silvers v. Google, Inc.

Filing 194

First MOTION for Extension of Time to File Statement of Disputed facts by Steven A. Silvers. (Cooper, Robert)

Silvers v. Google, Inc.

Doc. 194

Case 9:05-cv-80387-KLR

Document 194

Entered on FLSD Docket 11/17/2006

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CIVIL DIVISION CASE NO. 05-80387-CIV-RYSKAMP/VITUNAC Steven A. Silvers, an individual Plaintiff v. Google Inc., a Delaware corporation Defendant

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Silvers' Motion to Be Excused from Filing Separate State in a Disputed Facts or in the Alternative for an Extension of Time to File a Statement of Disputed Facts Silvers moves this Court to be excused from the requirement of filing a separate statement of disputed facts or in the alternative moves this Court for a 15 day extension of time to file a statement of disputed facts and as ground states: 1. The undersigned counsel has been diligently attempting to comply with this Court's filing deadlines under the present time constraints and under the limitation that the undersigned counsel has only recently appeared in this very complicated case. 2. The undersigned counsel did not have sufficient time to prepare his statement of contested facts. 3. However, the memorandum in opposition filed by Silvers has ample citations to the record and clearly sets forth the disputed facts. Accordingly, it would not prejudice either the Court or the other parties if Silvers were excused from 1

Dockets.Justia.com

Case 9:05-cv-80387-KLR

Document 194

Entered on FLSD Docket 11/17/2006

Page 2 of 2

the requirement of filing a separate statement of disputed facts. In fact, other than relying on the documents contained in the appendix filed by Stelor, Silvers only relies on a short two-page declaration of Silvers with one exhibit. 4. In the event this Court will not excuse Sivlers from the requirement of filing a separate statement of disputed facts, Silvers requests 15 days to file such a statement as the undersigned counsel will be starting a jury trial on Monday November 20th, 2006 and the Thanksgiving holiday also fall within the time frame requested.

Certificate of Service I certify that a true and correct copy of the foregoing was e-mailed and mailed first class mail this November 17, 2006 to the attached list:
Robert H. Cooper P.A. 2999 N.E. 191 St. Suite 704 Miami, Fl. 33180 305-792-4343 (direct extension) 305-792-0200 (fax) [e-mail] Fl. Bar No. 0650323 S/ Robert Cooper ____ Robert H. Cooper for the Firm.

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