Raanan Katz Motion For Extension Of Time

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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.

Case 1:12-cv-22211-JLK Document 15 Entered on FLSD Docket 08/24/2012 Page 1 of 4

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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


Email: [email protected]

and


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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



Josh E. Saltz




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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.

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


Counsel for Defendant, Irina

Chevaldina

[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



Chevaldina

[via CM/ECF]

Marc John Randazza, Esq.

6525 W. Warm Springs Rd., Suite 100

Las Vegas, NV 89118

Tel: 888-667-1113

Fax: 305-437-7662



Chevaldina

[via CM/ECF]


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Raanan Katz Motion For Extension Of Time