STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE FIRST AMENDED COMPLAINT AND ORDER THEREON
Complaint Filed: August 17, 2009
This Stipulation is made by and between plaintiffs Carmelo Anthony, Melo Enterprises, Inc. and Chosen One Properties, LLC (collectively "Plaintiffs") and defendants Larry Harmon aka Larry W. Harmon aka Lawrence Harmon; Larry Harmon & Associates, P.A., Harmon-Castillo, LLP, Frank Castillo, and Vitalis Partners, LLC (collectively "Defendants").
WHEREAS, on November 25, 2009, the Court entered an Order granting Defendants' motion to dismiss Plaintiff's complaint, and granting Plaintiffs thirty-days from the date of the November 25, 2009 Order to file an amended complaint. See Docket No. 26.
WHEREAS under the Court's November 25, 2009 Order, Plaintiffs current deadline to file their amended complaint falls on December 25, 2009, a federal holiday.
WHEREAS, counsel for Plaintiffs and Defendants have conferred and agreed that in light of the Holiday season and counsel's continuing communication with each other concerning the various claims and defenses of the parties, good cause exists to allow Plaintiffs an extension of time to file their amended complaint to January 8, 2010.
WHEREAS Plaintiffs do not intend to name Kelly Runkle, Sora Barnes, Professional Partners, LLC, and/or MCG Partners as defendants to the First Amended Complaint, therefore the consent of these parties to the present stipulation is not required.
WHEREAS the default of Defendants Kenny Cruz aka Kenneth Cruz and KC Development, LLC was previously taken, therefore the consent of these parties to the present stipulation is not required.
IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs and Defendants, that good cause exists to extend the time within which Plaintiffs may file their amended complaint from December 25, 2009 to January 8, 2010, and the parties respectfully request the Court to enter an Order thereon.
ROBERT W. HIRSH & ASSOCIATES
Robert W. Hirsh Attorneys for Plaintiffs Carmelo Anthony, Melo Enterprises, Inc. and ...