Stelor Productions, v. Silvers

Filing 72

MOTION by Stelor Productions (Attorney ) to extend time file amended complaint (dj, Deputy Clerk)

Stelor Productions, v. Silvers

Doc. 72

Case 9:05-cv-80393-DTKH

Document 72

Entered on FLSD Docket 08/22/2005

Page 1 of 3 Aug 19 2005

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 05-80393 CIV HURLEY/HOPKINS STELOR PRODUCTIONS, L.L.C., a Delaware limited liability company, f/k/a STELOR PRODUCTIONS, INC., Plaintiff, vs. STEVEN A. SILVERS, a Florida resident, Defendant. ________________________________________/ PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME TO FILE AMENDED COMPLAINT Plaintiff Stelor Productions, LLC ("Stelor"), by and through undersigned counsel, hereby moves on the following grounds for an enlargement of time to file its amended complaint: 1. Plaintiff is in the process of preparing its amended complaint and supplementary

evidentiary submissions in accordance with the Court's Order Granting Without Prejudice Defendant's Motion to Dismiss ("Order"). 2. Pursuant to that Order, the amended complaint and evidentiary submissions are

due to be filed on Monday, August 22, 2005. 3. Plaintiff, however, requires a few additional days to complete the amended

complaint and submissions, and respectfully requests a one-week enlargement of time. As cause for the requested enlargement, health concerns of Stelor's CEO have limited his availability, and the assembly of the additional information needed for the amendment is not yet completed. Stelor requires the additional time to complete the process, and ensure that the amended complaint is filed with accurate and complete information.

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Case 9:05-cv-80393-DTKH

Document 72

Entered on FLSD Docket 08/22/2005

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CASE NO. 05-80393 CIV HURLEY/HOPKINS

4. Defendant. 5.

The enlargement is not requested for purposes of delay, and will not prejudice the

Undersigned counsel has advised opposing counsel of the requested enlargement,

but they do not agree. WHEREFORE, Plaintiff respectfully requests an enlargement of time up to and including August 29, 2005, to file its amended complaint and supplementary evidentiary submissions. BURLINGTON, WEIL, SCHWIEP, KAPLAN & BLONSKY, P.A. Attorneys for Plaintiff Office in the Grove, Penthouse A 2699 South Bayshore Drive Miami, Florida 33133 Tel: [phone] Fax: [phone] Email: [e-mail] By: /s/ Kevin C. Kaplan Kevin C. Kaplan Florida Bar No. 933848 David J. Zack Florida Bar No. 641685 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was served via electronic mail and U.S. mail on this 19th day of August, 2005 upon the following: Adam T. Rabin, Esq. DIMOND, KAPLAN & ROTHSTEIN, P.A. Suite 708 200 S.E. First Street Miami, Florida 33131 Kenneth R. Hartmann, Esq. Gail M. McQuilkin, Esq. KOZYAK TROPIN & THROCKMORTON, P.A. 2525 Ponce de Leon Blvd., 9th Floor Coral Gables, Florida 33134 /s/ Kevin C. Kaplan Kevin C. Kaplan 2

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Case 9:05-cv-80393-DTKH

Document 72

Entered on FLSD Docket 08/22/2005

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UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 05-80393-Civ-Hurley/Hopkins STELOR PRODUCTIONS, L.L.C., a Delaware limited liability company, f/k/a STELOR PRODUCTIONS, INC., Plaintiff, vs. STEVEN A. SILVERS, a Florida resident, Defendant. ________________________________________/ PROPOSED ORDER GRANTING PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME TO FILE AMENDED COMPLAINT This matter came before the Court on Plaintiff STELOR PRODUCTIONS, L.L.C., f/k/a STELOR PRODUCTIONS, INC.'s ("Stelor") Motion for Enlargement of Time to File Amended Complaint. Having reviewed the Motion, and being otherwise fully advised in the premises, it is hereby ORDERED AND ADJUDGED as follows: 1. 2. The Motion is hereby GRANTED. Plaintiff shall have up to and including August 29, 2005 to file its amended

complaint and supplementary evidentiary submissions pursuant to the Court's Order Granting Defendant's Motion to Dismiss Without Prejudice. DONE and ORDERED in Chambers at West Palm Beach, Florida, this ____ day of August, 2005. ________________________________ UNITED STATES DISTRICT JUDGE cc: Kenneth R. Hartmann, Esq. Kevin C. Kaplan, Esq. Adam T. Rabin, Esq.

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