Consent MOTION for Extension of Time to File Answer regarding 1 Complaint,,,,,,, filed… — Blueacorn Beringer (Dkt. 47)

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                   IN THE UNITED STATES DISTRICT COURT
               FOR THE EASTERN DISTRICT OF NORTH CAROLINA
                             WESTERN DIVISION
                       CIVIL ACTION NO. 5:21-CV-251-BO

 BERINGER COMMERCE, INC. d/b/a                 )
 BLUE ACORN iCi,                               )
                                               )
                           Plaintiff,          )
                                               )
                     vs.                       )
                                               ) MOTION FOR EXTENSION OF TIME
 FIN CAP, INC. d/b/a “BLUEACORN.CO,”           )   TO ANSWER OR OTHERWISE
 BLUE ACORN PPP, LLC, BLUE OAK                 )    RESPOND TO PLAINTIFF’S
 FOREST, LLC, MICHAEL S. COTA,                 )          COMPLAINT
 JAMES FLORES, STEPHANIE                       )
 HOCKRIDGE REIS, and NATHAN REIS,              )        (WITH CONSENT)
                                               )
                           Defendants.         )

        Defendants James Flores, Stephanie Hockridge Reis, and Nathan Reis

(“Defendants”), by and through undersigned counsel, move this Court, pursuant to

Federal Rule of Civil Procedure 6(b), for an extension of time up to and including July

30, 2021, within which to answer or otherwise plead in response to the Complaint.

In support of the motion, Defendants show the Court as follows:

        1.   Plaintiffs have filed affidavits of service of the summons and complaint

reflecting delivery by Federal Express to certain persons on June 16, 2021.

        2.   Undersigned counsel was contacted regarding this matter on July 19,

2021.

        3.   Rather than contest service, undersigned counsel contacted counsel for

Plaintiff and requested an agreed extension of time to respond to the Complaint.




        Case 5:21-cv-00251-BO       Document 47   Filed 07/20/21    Page 1 of 3
      4.     Counsel for Plaintiff has consented to an extension of time up through

and including July 30, 2021.

      5.     No prior extension has been granted by the Court to these Defendants.

      WHEREFORE, Defendants James Flores, Stephanie Hockridge Reis, and

Nathan Reis request that this Court enter an order extending the time within which

they must answer or otherwise respond to the Complaint up through and including

July 30, 2021.

      This the 20th day of July, 2021.

                                 GRAEBE HANNA & SULLIVAN, PLLC

                                 /s/ Christopher T. Graebe
                                 Christopher T. Graebe, NCSB No. 17416
                                 4350 Lassiter at North Hills Ave., Suite 375
                                 Raleigh, North Carolina 27609
                                 Telephone: 919-863-9092
                                 Facsimile: 919-424-6407
                                 Email:       cgraebe@ghslawfirm.com
                                 Counsel for James Flores, Stephanie Hockridge Reis,
                                 and Nathan Reis




       Case 5:21-cv-00251-BO      Document 47    Filed 07/20/21   Page 2 of 3
                          CERTIFICATE OF SERVICE


       I hereby certify that on July 20, 2021, I electronically filed the foregoing
document with the Clerk of the Court using the CM/ECF system which will send
notification of such filing to all counsel of record.

      This the 20th day of July, 2021.

                                /s/ Christopher T. Graebe
                                Christopher T. Graebe, NCSB No. 17416
                                4350 Lassiter at North Hills Ave., Suite 375
                                Raleigh, North Carolina 27609
                                Telephone: 919-863-9092
                                Facsimile: 919-424-6407
                                Email:       cgraebe@ghslawfirm.com
                                Counsel for James Flores, Stephanie Hockridge Reis,
                                and Nathan Reis




       Case 5:21-cv-00251-BO     Document 47    Filed 07/20/21   Page 3 of 3


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