![Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 1 of 4
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No.: 1:12-cv-22211-JLK
RAANAN KATZ,
Plaintiff,
vs.
IRINA CHEVALDINA,
Defendant.
_______________________________________/
PLAINTIFF’S FIRST MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANT’S SECOND MOTION TO DISMISS
Plaintiff, Raanan Katz, by and through his undersigned counsel, hereby moves for an
extension of time to respond to Defendant’s Motion to Dismiss the Amended Complaint [the
“Second Motion to Dismiss,” DE 14], and states:
1. The current deadline to respond to the Second Motion to Dismiss is August 27,
2012.
2. Undersigned counsel (Michael B. Chesal) has just returned on the afternoon of
August 21st from a two and one half week trip out of the country.
3. Defendant’s Second Motion to Dismiss with its attached Exhibits exceeds over
200 pages and seeks dismissal of the Amended Complaint with prejudice. Plaintiff’s counsel is
preparing a substantive response but will need additional time given the nature of the motion
coupled with being out of the office when the motion was served.
4. Undersigned counsel is only seeking a ten (10) day extension of time to respond,
up to and including September 6, 2012 in order to adequately respond to Defendant’s Second
Motion to Dismiss.
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Raanan Katz Motion For Extension Of Time
- 1. Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 1 of 4 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No.: 1:12-cv-22211-JLK RAANAN KATZ, Plaintiff, vs. IRINA CHEVALDINA, Defendant. _______________________________________/ PLAINTIFF’S FIRST MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S SECOND MOTION TO DISMISS Plaintiff, Raanan Katz, by and through his undersigned counsel, hereby moves for an extension of time to respond to Defendant’s Motion to Dismiss the Amended Complaint [the “Second Motion to Dismiss,” DE 14], and states: 1. The current deadline to respond to the Second Motion to Dismiss is August 27, 2012. 2. Undersigned counsel (Michael B. Chesal) has just returned on the afternoon of August 21st from a two and one half week trip out of the country. 3. Defendant’s Second Motion to Dismiss with its attached Exhibits exceeds over 200 pages and seeks dismissal of the Amended Complaint with prejudice. Plaintiff’s counsel is preparing a substantive response but will need additional time given the nature of the motion coupled with being out of the office when the motion was served. 4. Undersigned counsel is only seeking a ten (10) day extension of time to respond, up to and including September 6, 2012 in order to adequately respond to Defendant’s Second Motion to Dismiss. {00030418.1 : 8/24/2012 03:35 PM } 1 of 4
- 2. Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 2 of 4 5. This request is made in good faith and not for purposes of undue delay and will not unduly prejudice any of the parties involved in this action. 6. In accordance with Local Rule 7.1(a)(3)(A), counsel for the movant certifies he has conferred with counsel for the Defendant in a good faith effort to resolve the issues raised in this motion but has been unable to do so. For some reason, counsel for the Defendant refuses to agree to the brief requested extension (even though undersigned counsel previously consented to an extension of time requested by Defendant’s counsel). 7. A proposed order granting the requested relief is submitted herewith. WHEREFORE, Plaintiff respectfully requests that the deadline to respond to Defendant’s Second Motion to Dismiss be extended to September 6, 2012. Dated: August 24, 2012 Respectfully submitted, KLUGER KAPLAN SILVERMAN KATZEN & LEVINE, P.L. Co-Counsel for Raanan Katz 201 South Biscayne Blvd., 17th Floor Miami, Florida 33131 Telephone: 305-379-9000 Facsimile: 305- 379-3428 By: /s Alan J. Kluger Alan J. Kluger Florida Bar No. 200379 Email: akluger@ klugerkaplan.com Todd A. Levine Florida Bar No. 899119 Email: tlevine@klugerkaplan.com and {00030418.1 : 8/24/2012 03:35 PM } 2 of 4
- 3. Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 3 of 4 PERETZ CHESAL & HERRMANN, P.L. Co-Counsel for Raanan Katz 201 South Biscayne Blvd., Suite 1750 Miami, Florida 33131 Telephone: 305-341-3000 Facsimile: 305-371-6807 By: /s Michael B. Chesal Michael B. Chesal Florida Bar No. 775398 Email: mchesal@pch-iplaw.com Josh E. Saltz Florida Bar No. 70521 Email: jsaltz@pch-iplaw.com {00030418.1 : 8/24/2012 03:35 PM } 3 of 4
- 4. Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 4 of 4 CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was served on August 24, 2012 on all counsel or parties of record in the manner specified on the Service List below. /s Michael B. Chesal SERVICE LIST Robert Charles Kain, Jr., Esq. Marc John Randazza, Esq. Kain & Associates, Attorneys at Law, 6525 W. Warm Springs Rd., Suite 100 P.A. Las Vegas, NV 89118 900 SE Third Avenue, Suite 205 Tel: 888-667-1113 Fort Lauderdale, FL 33316 Fax: 305-437-7662 Tel: 954-768-9002 Email: MJR@randazza.com Fax: 954-768-0158 Counsel for Defendant, Irina Email: rkain@complexip.com Chevaldina Counsel for Defendant, Irina Chevaldina [via CM/ECF] [via CM/ECF] Darren Joel Spielman, Esq. Kain & Associates, Attorneys at Law, P.A. 900 SE Third Avenue, Suite 205 Fort Lauderdale, FL 33316 Tel: 954-768-9002 Fax: 954-768-0158 Email: dspielman@complexip.com Counsel for Defendant, Irina Chevaldina [via CM/ECF] {00030418.1 : 8/24/2012 03:35 PM } 4 of 4