`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE MIDDLE DISTRICT OF FLORIDA
`ORLANDO DIVISION
`
`LIGHTING SCIENCE GROUP
`CORPORATION,
`
`Plaintiff.
`
`v.
`
`Case No.: 6:16-CV-00680-RBD-GJK
`
`ENERGY EFFICIENT LIGHTING
`COMPANY LIMITED,
`
`Defendant.
`
`___________________________________/
`
`DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND
`TO COMPLAINT AND INCORPORATED MEMORANDUM OF LAW
`
`Defendant, Energy Efficient Lighting Company Limited (“the Defendant”), by and
`
`through undersigned counsel, requests an Order granting the Defendant an extension of time
`
`until October 17, 2016 in order to file its response to the Second Amended Complaint (Doc. #23).
`
`In support of this Motion, the Defendant states:
`
`1.
`
`On August 24, 2016, the Plaintiff, Lighting Science Group Corporation (the
`
`“Plaintiff”), filed its Second Amended Complaint against the Defendant (Doc. #23)(“the
`
`Complaint”).
`
`2.
`
`On August 26, 2016, the Defendant was served with the Summons and the
`
`Complaint. Pursuant to applicable law, the Defendant’s response to the Complaint is currently
`
`due on September 16, 2016.
`
`3.
`
`By the filing of this Motion, the Defendant hereby requests a thirty (30) day
`
`extension of time (i.e., until on or before October 17, 2016) to file its response to the Complaint.
`
`Page 1 of 3
`
`
`
`Case 6:16-cv-00680-RBD-GJK Document 30 Filed 09/16/16 Page 2 of 3 PageID 448
`
`Good cause exists for the Court to grant the requested extension of time. Counsel for Defendant
`
`and counsel for Plaintiff wish to explore possible settlement of the dispute, potentially obviating
`
`the need for the parties and the Court to expend further resources.
`
`4.
`
`Pursuant to Local Rule 3.01(g), undersigned counsel certifies that counsel for the
`
`Defendant, namely, Felix J. Gilman, has conferred with counsel for Plaintiff concerning the relief
`
`requested by Defendant in this Motion. Counsel for Plaintiff does not oppose the relief requested
`
`herein.
`
`Memorandum of Law
`
`Pursuant to Local Rule 3.01(a), the Defendant submits this Memorandum of Law in
`
`support of its Unopposed Motion for Extension of Time to Respond to Complaint. The applicable rules
`
`of procedure permit this Court, in its discretion, to enlarge a period of time “for good cause”
`
`when a request is made prior to the expiration of time originally allowed. See Fed. R. Civ. P.
`
`6(b)(1). The foregoing allegations constitute such good cause, and would justify the exercise of
`
`the Court’s discretion to grant this unopposed motion.
`
`WHEREFORE, the Defendant requests an Order granting the Defendant an extension of
`
`time up to and including October 17, 20161 in order to file its response to the Second Amended
`
`Complaint (Doc. #23), or awarding any other relief deemed just and proper.
`
`Date: September 16, 2016.
`
`Respectfully submitted,
`
`EWUSIAK LAW, P.A.
`
`/s/ Joel Ewusiak
`
`1 Thirty (30) days after September 16, 2016 is Sunday, October 16, 2016. Monday, October 17, 2016 is the
`next business day.
`
`Page 2 of 3
`
`
`
`Case 6:16-cv-00680-RBD-GJK Document 30 Filed 09/16/16 Page 3 of 3 PageID 449
`
`Joel Ewusiak
`Fla. Bar No.: 0509361
`6601 Memorial Highway, Suite 311
`Tampa, FL 33615
`P:
`727.286.3559
`F:
`727.286.3219
`E:
`joel@ewusiaklaw.com
`Counsel for Defendant, Energy Efficient Lighting
`Company Limited
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that, on September 16, 2016, the foregoing document was
`
`electronically filed using the CM/ECF system, which will send notice of electronic filing to all
`
`counsel of record.
`
`/s/ Joel Ewusiak
`Joel Ewusiak
`
`Page 3 of 3
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