MOTION to Extend Time (Corrected) (Unopposed) for An Extension of time to Respond to… — Agent Fee Litigation (Dkt. 30)

Summary

Defendant ServisFirst Bank's corrected unopposed motion for an extension of time to respond to the amended complaint in Sport & Wheat CPA PA v. ServisFirst Bank Inc., Case No. 3:20-cv-05425-TKW-HTC, in the U.S. District Court for the Northern District of Florida, submitted June 1, 2020 (Dkt. 30). The motion asks that ServisFirst's response deadline be extended until June 17, 2020. It states that the plaintiff filed the amended complaint on May 27, 2020, that ServisFirst accepted service that day, and that a May 28, 2020 Order set a June 11, 2020 deadline for parties previously served. ServisFirst reserves its defenses and states no party would be prejudiced. The filing is signed by counsel at Lightfoot, Franklin & White, LLC and includes a certificate of service.

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                         IN THE UNITED STATES DISTRICT COURT
                        FOR THE NORTHERN DISTRICT OF FLORIDA
                                 PENSACOLA DIVISION

SPORT & WHEAT CPA PA, a Florida                   )
corporation, individually and on behalf           )
of a class of similarly situated businesses       )
and individuals,                                  )
                                                  )
        Plaintiff,                                )
                                                  )
v.                                                )   Case No. 3:20-cv-05425-TKW-HTC
                                                  )
SERVISFIRST BANK INC., SYNOVUS                    )   UNOPPOSED
TRUST COMPANY, NATIONAL                           )
ASSOCIATION and DOES 1-100,                       )
inclusive,                                        )
                                                  )
        Defendants.                               )

     DEFENDANT SERVISFIRST BANK’S CORRECTED UNOPPOSED MOTION FOR AN
         EXTENSION OF TIME TO RESPOND TO THE AMENDED COMPLAINT

        Defendant ServisFirst Bank (“ServisFirst”) moves the Court for an Order extending its time

to respond to the Amended Complaint until June 17, 2020, showing the Court as follows:

        1.      Plaintiff filed an Amended Complaint on May 27, 2020. (Doc. # 21)

        2.      ServisFirst accepted service of the Amended Complaint the same day and agreed

with Plaintiff’s counsel that its response deadline was twenty-one days thereafter on June 17, 2020.

        3.      On May 28, 2020, this Court entered an Order stating that the response deadline for

all parties previously served would be June 11, 2020. (Doc. # 22).

        4.      Since ServisFirst accepted service the day before the Court’s Order, its response to

the Amended Complaint would be due, per the Order, on June 11, 2020. ServisFirst respectfully

requests that it be permitted until June 17, 2020, the date required by the Federal Rules of Civil

Procedure and agreed upon with Plaintiff, to respond to the Amended Complaint.




                                                 1
        5.      ServisFirst expressly reserves and does not waive any defenses it otherwise may

assert in this action.

        6.      No party would be prejudiced by the requested extension.

        WHEREFORE, Defendant ServisFirst Bank respectfully moves the Court to enter an order

extending until June 17, 2020, its time to respond to the Amended Complaint.

        Respectfully submitted this 1st day of June, 2020.



                                             /s/ Logan T. Matthews
                                             Logan T. Matthews
                                             Florida Bar No. 1002506
                                             LIGHTFOOT, FRANKLIN & WHITE, LLC
                                             The Clark Building
                                             400 20th Street North
                                             Birmingham, Alabama 35203
                                             Telephone: (205) 581-0700
                                             Facsimile: (205) 581-0799

                                             One of the Attorneys for Defendant
                                             ServisFirst Bank


OF COUNSEL:
Sara A. Ford (pro hac vice application forthcoming)
sford@lightfootlaw.com
R. Ashby Pate (pro hac vice application forthcoming)
apate@lightfootlaw.com
Logan T. Matthews (Florida Bar No. 1002506)
lmatthews@lightfootlaw.com
LIGHTFOOT, FRANKLIN & WHITE, LLC
The Clark Building
400 20th Street North
Birmingham, Alabama 35203
Telephone: (205) 581-0700
Facsimile: (205) 581-0799




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                                   CERTIFICATE OF SERVICE

        I hereby certify that on this 1st day of June, 2020, I electronically filed the foregoing with

the Clerk of the Court using the CM/ECF system which will send electronic notification of such

filing to all counsel of record.

                                               /s/ Logan T. Matthews
                                               One of the Attorneys for Defendant
                                               ServisFirst Bank




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