Wyndham Vacation Ownership, Inc. et al v. CLS, Inc. et al

Southern District of Florida, flsd-9:2018-cv-81250

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to {{70}} Amended Complaint, by Bart Bowe, Real Travel, LLC, Brian Scroggs, The Transfer Group, LLC, VCS Communications, LLC, Vacation Consulting Services, LLC.

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA WEST PALM BEACH DIVISION CASE NO. 9:18-cv-81250-WPD WYNDHAM VACATION OWNERSHIP, INC. a Delaware corporation; WYNDHAM VACATION RESORTS, INC., a Delaware corporation, WYNDHAM RESORT DEVELOPMENT CORPORATION; an Oregon Corporation, SHELL VACATIONS, LLC, an Arizona limited liability company; SVC-WEST, LLC, a California limited liability company; SVC-AMERICANA, LLC, an Arizona limited liability company; and SVC-HAWAII, LLC, a Hawaii limited liability company, Plaintiffs, v. CLAPP BUSINESS LAW, LLC, a Missouri limited liability company; MARY CLAPP, ESQ., an individual; THE TRANSFER GROUP, LLC, a Missouri limited liability company; VACATION CONSULTING SERVICES, LLC, a Missouri limited liability company; VCS COMMUNICATIONS, LLC, a Missouri limited liability company; REAL TRAVEL, LLC, an Arkansas limited liability company; and BART BOWE, an individual; BRIAN SCROGGS, an individual; TRANSFER FOR YOU LLC, a Missouri limited liability company; ALLIED SOLUTION GROUP, LLC, a Missouri limited liability company; JJ MIDWEST MARKETING LLC, a Missouri limited liability company; JJ&C MARKETING, LLC, a Missouri limited liability company; THE MID-WEST TRANSFER, LLC, a Missouri limited liability company; MIDWEST TRANSFERS LLC, a Missouri limited liability company; and JOSH UNGARO, an individual, Defendants. ________________________________________________________________________ 1 DEFENDANTS, THE TRANSFER GROUP, LLC, VACATION CONSULTING SERVICES, LLC, VCS COMMUNICATIONS, LLC, BRIAN SCROGGS, REAL TRAVEL, LLC, AND BART BOWE'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO PLAINTIFFS' AMENDED COMPLAINT COME NOW, Defendants, THE TRANSFER GROUP, LLC, VACATION CONSULTING SERVICES, LLC, VCS COMMUNICATIONS, LLC, BRIAN SCROGGS, REAL TRAVEL, LLC, and BART BOWE (collectively the "Moving Defendants"), by and through the undersigned attorney, and move this Honorable Court for an extension of time to file a response to Plaintiffs' Amended Complaint [Doc. 70] (the "Amended Complaint") until January 14, 2019 and states: 1. Plaintiffs filed their Amended Complaint for damages and injunctive relief on December 10, 2018. 2. The Amended Complaint raises many complex issues of both law and fact. 3. The Amended Complaint asserts five (5) causes of action against the Moving Defendants, including a Civil Conspiracy among all named defendants "to interfere with existing contractual relations" between Plaintiffs and its consumer timeshare owners. See Doc. 70 ¶¶ 219-231. 4. Compared to Plaintiffs' original Complaint dismissed by the Court as a "shotgun" pleading [Doc. 1, 58], the Amended Complaint makes additional and different allegations against the Moving Defendants and includes added exhibits. 5. The undersigned counsel respectfully requests an extension of time through January 14, 2019 to file a response to the Amended Complaint on behalf of the Moving Defendants. The additional time is needed to investigate the Amended Complaint's allegations and properly frame adequate response(s) to the Amended Complaint. 6. The extension sought herein is not made for purpose of delay, and if granted, will not prejudice any party. CERTIFICATE OF GOOD FAITH CONFERENCE 2 7. Pursuant to Local Rule 7.1(a)(3)(B), I hereby certify that counsel for the Moving Defendants conferred with Plaintiffs' counsel and Plaintiffs' counsel does not oppose the extension requested herein. WHEREFORE, the Moving Defendants, respectfully requests that this Court grant the enlargement of time through January 14, 2019 to respond to the Amended Complaint. Dated: December 18, 2018. /s Shannon Zetrouer Shannon L. Zetrouer, Esq. Fla. Bar No. 16237 Meyer Zetrouer, P.A. 9355 113th St. N. # 4250 Seminole, Florida 33775 Telephone- 727/440-4407 Primary E-mail: szetrouer@meyerzetrouer.com Secondary: tpulsifer@meyerzetrouer.com eschoos@meyerzetrouer.com CERTIFICATE OF SERVICE I CERTIFY that a copy of the foregoing was electronically filed with the Clerk of Court by using the CM/ECF system on December 18, 2018. /s Shannon Zetrouer Shannon L. Zetrouer, Esq. 3