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Case 8:11-cv-02269-JDW-TGW Document 8 Filed 11/09/11 Page 1 of 2 PageID 38



UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA

TAMPA DIVISION


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











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



Plaintiff,











v.

PREFERRED COLLECTION AND
MANAGEMENT SERVICES, INC.,

a Florida corporation,






_____________________________________/



Defendant.




























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 2, 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 2,

2011.

MEMORANDUM IN SUPPORT

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

to Defendants’ Motion to Dismiss is currently due to be served on November 18, 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 8 Filed 11/09/11 Page 2 of 2 PageID 39


including December 2, 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 Unopposed Motion for Extension

of Time to Respond to Defendant’s Motion to Dismiss has been furnished electronically or
via U.S. Mail this 9th day of November 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