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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA


No.09:1l-cv-80880-KLR
QSGI, Inc., a Delaware Corporation,
Plaintiff,
v.
IBM GLOBAL FINANCING, a Division of
International Business Machines Corp., and
INTERNATIONAL BUSINESS MACHINES
CORP., Parent to andlor d/bla IBM GLOBAL
FINANCING,
Defendants.
__________________________ ~ I
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO
DEFENDANTS' MOTION TO DISMISS SECOND AMENDED COMPLAINT
Plaintiff, by and through undersigned counsel, hereby files this Motion for Extension of
Time to File Response to Defendants' Motion to Dismiss Second Amended Complaint pursuant
to Fed. R. Civ. P. 6(b)(I) and Local Rule 7.1. In support thereof, Plaintiff states as follows:
1. Plaintiffs Response to Defendants' Motion to Dismiss Second Amended
Complaint is due Thursday, May 3, 2012.
2. Plaintiff's counsel responsible for drafting Plaintiff s Response has been away
from his office eight (8) out of the preceding ten (10) busim-ss days covering depositions in two
separate lawsuits set for trial in Boston, Massachusetts and Ft. Lauderdale, Florida. See, Robert
Stead et al. v. Georgia-Pacific LLC; Case No. 09-4917, Superior Court for Middlesex County,
Massachusetts; and Donald Bolton et al. v. ACandS, Inc., Cale No. 00-10831, In the 17
th
Judicial
Circuit in and for Broward County, Florida. Plaintiffs cO'lllsel will also be out of the office
taking the videotaped deposition of a dying client outside of)eltona, Florida, April 30 to May 2,
Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 1 of 3
2012. See, Bernard Harmon et al. v. Borg Warner Corp., Caf:e No. 11-4289, In the 17'h Judicial
Circuit in and for Broward County, Florida.
3. Given Plaintiffs counsel's inconvenient sch,:dule during the past and coming
weeks Plaintiff requests a short ten (10) day extension of 1ime to file Plaintiffs Response to
Defendants' Motion to Dismiss Second Amended Complaint.
4. This is Plaintiff first request for an extension of time to file its Response to
Defendants' Motion to Dismiss Second Amended Complaint.
5. Plaintiffs counsel conferred with Defendants counsel, and Defendants object to
Plaintiffs request for a 10-day extension of time to file Plaintiffs Response.
WHEREFORE, for the reasons set forth herein, Plaintiff respectfully requests that this
Court enter an Order Granting Motion for Extension of Time to File Response to Defendants'
Motion to Dismiss Second Amended Complaint.
By:
Respectfilll y submitted,
THE FERRARO LAW FIRM, P.A.
AttorneYifor the Plaintiff
4000 Por:ce de Leon Blvd.
Suite 70(
Miami, FL 33146
Telephone (305) 375-0111
Facsimik (305) 379-6222
("' __ _
2
CASE A DAM, ES .
Florida Bar No. 756091
Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 2 of 3
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CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the for egoing was served via CMlECF on
all counsel of record this
C
THE .
. }
. ..

Florida Bar No. 756091
3
Case 9:11-cv-80880-KLR Document 60 Entered on FLSD Docket 04/27/2012 Page 3 of 3
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO: 11-80880-CIV-RYSKAMP\vITUNAC
QSGI, Inc., a Delaware Corporation,
Plaintiff,
v.
IBM GLOBAL FINANCING, et al.
Defendants.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ /
ORDER GRANTING PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE
RESPONSE TO DEFENDANTS' MOTION TO DISMISS SECOND AMENDED
COMPLAINT
THIS CAUSE having come before the Court on Plain:iff's Motion for Extension of Time
to File Response to Defendants' Motion to Dismiss Second Amended Complaint and the Court
having considered Plaintiff's Motion and being fully advised in the premises, it is hereupon:
ORDERED AND ADJUDGED:
I. Plaintiff's Motion is GRANTED.
2. Plaintiff shall file its Response to Defendants' Motion to Dismiss Second Amended
Complaint on or before May 14,2012.
DONE AND ORDERED in Chambers at West Palm Beach, Florida, this ___ day of
____________ ,,2012.
KENNE'cH L. RYSKAMP
UNITED STATES DISTRICT JUDGE
Case 9:11-cv-80880-KLR Document 60-1 Entered on FLSD Docket 04/27/2012 Page 1 of 1