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Case 8:11-cv-02269-JDW-TGW Document 10 Filed 12/01/11 Page 1 of 2 PageID 40



UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION





Case No.: 8:11-cv-2269-JDW-TGW


RICHARD M. DAUVAL, Trustee for the
estate of Joseph Pietro, an individual,









Plaintiff,











v.

PREFERRED COLLECTION AND
MANAGEMENT SERVICES, INC.,

a Florida corporation,






_____________________________________/



Defendant.




























SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF

TIME TO FILE RESPONSE TO DEFENDANT’S MOTION TO DISMISS

COMES NOW Plaintiff, RICHARD DAUVAL, as Trustee for the estate of Joseph

Pietro (hereinafter, “Plaintiff”), by and through the undersigned counsel, and respectfully

requests that this Court extend the time for Plaintiff to file his response to Defendant’s

Motion to Dismiss [Dkt. 6] until December 16, 2011. Plaintiff submits the below

memorandum in support of his motion.

WHEREFORE, Plaintiff respectfully requests this Court enter an order extending

the time for Plaintiff to file his response to Defendant’s Motion to Dismiss until December

16, 2011.

MEMORANDUM IN SUPPORT

Defendant filed its Motion to Dismiss on November 4, 2011. Plaintiff’s response to

Defendants’ Motion to Dismiss is currently due to be served on December 2, 2011. Due to

the complexity of issues raised in Defendant’s Motion to Dismiss, as well as other

obligations of Plaintiff’s counsel, Plaintiff requests a short extension of time, through and



Case 8:11-cv-02269-JDW-TGW Document 10 Filed 12/01/11 Page 2 of 2 PageID 41


including December 14, 2011, in which to file his response to Defendant’s Motion to

Dismiss. This request is made for good cause and not for purposes of delay.

CERTIFICATE OF CONFERENCE

Pursuant to Local Rule 3.01(g), counsel for Plaintiff has conferred with counsel for

Defendant and Defendant does not oppose the requested extension of time.

Respectfully Submitted,
LEAVENGOOD & NASH

/s/ Ian R. Leavengood
Ian R. Leavengood, Esq., FBN 0010167
LEAD TRIAL COUNSEL
Christopher C. Nash, Esq., FBN 135046
Heather M. Fleming, Esq. FBN 25971
2958 First Avenue North
St. Petersburg, FL 33713
Phone: (727) 327-3328
Fax: (727) 327-3305
[email protected]
[email protected]
[email protected]
Attorneys for Plaintiff

CERTIFICATE OF SERVICE




I HEREBY CERTIFY that a copy of the foregoing Second Unopposed Motion for

Extension of Time to Respond to Defendant’s Motion to Dismiss has been furnished
electronically or via U.S. Mail this 1st day of December 2011 to:

J. Robert McCormack
Counsel for Defendant
Lewis Brisbois Bisgaard & Smith, LLP
3812 Coconut Palm Drive, Suite 200
Tampa, FL 33619








/s/ Ian R. Leavengood
Attorney