Molina et al v. Ace Homecare LLC

Middle District of Florida, flmd-8:2016-cv-02214

Joint MOTION to extend time to 1/9/18 File Pre Trial Statement by All Plaintiffs.

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PageID 733 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION TONI MOLINA, ERICA TOVAR, TARA WARD, LY NGUYEN, CONSUELO POWELL, DONALD HALL and DEBBIE BURGESS, Plaintiffs, v. CASE NO.: 8:16-cv-02214-JDW-TGW ACE HOMECARE, LLC, BRL INVESTMENTS, LLC, ARTHUR BARLAAN, and J OCELYN BARLAAN, Defendants. ____________________________________/ JOINT MOTION FOR EXTENSION OF TIME TO FILE PRETRIAL STATEMENT Plaintiffs and Defendants, by and through their undersigned counsel, file this Motion asking the Court to extend the deadline for the parties to file their joint pre-trial statement by seven days, making the new pretrial statement deadline January 9, 2018. Importantly, no other deadlines will be affected by this extension. In support of their Motion, the Parties state as follows: 1. Pursuant to the Court's Case Management Report and Scheduling Order, the Parties' deadline to file their Pretrial Statement is January 2, 2018. (Dkt. 22). 2. Due to office closures for the Christmas and New Year holidays as well as the illness of both counsels, the Parties respectfully request a seven day extension of their deadline to file the Pretrial Statement, making the Parties' new deadline January 9, 2018. 3. This extension of time will not impact any other deadlines in this case. PageID 734 4. This motion is filed in good faith and not for the purpose of delay. No party will be prejudiced by the granting of the relief requested in this motion. MEMORANDUM OF LAW When an act is required or allowed to be done at or within a specified time, the Court for cause shown may at any time in its discretion, with or without motion or notice, order the period enlarged if such a request is made before the expiration of the period originally prescribed or as extended by previous order. See Fed. R. Civ. P. 6(b). The instant motion is brought before the Parties deadline to file their Joint Pretrial Statement. The parties respectfully suggests cause has been shown for the requested enlargement. WHEREFORE, the parties respectfully requests the Court extend the parties deadline to file the Joint Pretrial Statement to January 9, 2018. DATED this 29th day of December, 2017. THE SOLOMON LAW GROUP, P.A. WENZEL FENTON CABASSA, P.A. 1881 West Kennedy Boulevard 1110 North Florida Avenue Tampa, FL 33606 Suite 300 Telephone: (813) 225-1818 Tampa, Florida 33602 Facsimile: (813) 225-1050 Telephone: (813) 224-0431 Facsimile: (813) 229-8712 BY: /s/Blake J. Fredrickson BY: /s/Brandon J. Hill_ Blake J. Fredrickson Brandon J. Hill Florida Bar Number: 91086 Florida Bar Number: 37061 E-mail: bfredrickson@solomonlaw.com E-mail: bhill@wfclaw.com Counsel for Defendants Counsel for Plaintiff 2