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Amended MOTION for Extension of Time filed by Beringer Commerce, Inc — Blueacorn Beringer (Dkt. 61)

Summary

An Amended Motion for Extension of Time, Document 61 filed 12/06/21 in Civil Action No. 5:21-CV-251-BO, Beringer Commerce, Inc. d/b/a Blue Acorn iCi v. Fin Cap, Inc. d/b/a Blueacorn.co, Blue Acorn PPP, LLC and Blue Oak Forest, LLC, in the U.S. District Court for the Eastern District of North Carolina. Plaintiff Blue Acorn iCi asks under Rule 6(b) for more time to respond to defendants' first interrogatories and requests for production, which defendants served on November 16, 2021. It asks for time through and including January 10, 2022 and states that counsel for defendants consents. The motion is dated December 6, 2021 and signed by Beth A. Stanfield of Forrest Firm, P.C.

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“Amended MOTION for Extension of Time filed by Beringer Commerce, Inc — Blueacorn Beringer (Dkt. 61).” Original at ecf.nced.uscourts.gov, No. 5:21-cv-00251-BO, Doc. 61. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/blueacorn-beringer-nced-187990/undated-gov-uscourts-nced-187990-61-0-gov-uscourts-nced-187990-61-0/, SHA-256 83c96612104b1951738bb3f22248a52ebf10c496047eeb0173d44b29562dad4f.

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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,

                                 v.                         AMENDED
                                                   MOTION FOR EXTENSION OF TIME
 FIN CAP, INC. d/b/a “BLUEACORN.CO,”
 BLUE ACORN PPP, LLC, and BLUE OAK
 FOREST, LLC,

                      Defendants.

       NOW COMES Plaintiff BERINGER COMMERCE, INC. d/b/a BLUE ACORN iCi,

(“Blue Acorn iCi”) by and through the undersigned counsel, pursuant to Rule 6(b) of the Federal

rules of Civil Procedure and Local Rule 7.1(a), for good cause shown, and respectfully moves for

an extension of time to serve a response to Defendants FIN CAP, INC. d/b/a “BLUEACORN.CO,”

BLUE ACORN PPP, LLC, and BLUE OAK FOREST, LLC, (“Defendants”) First Set of

Interrogatories and First Requests of Production of Documents (“Discovery Requests”). In support

of this Motion, Plaintiff states as follows:

       1.       On June 10, 2021 Plaintiff filed its Complaint in the Eastern District of North

Carolina [DE-1].

       2.       On November 16, 2021 Defendants served Plaintiff with their Discovery Requests.

       3.       The file for serving a response to Defendants’ Discovery Requests has not yet

expired.

       4.       This Motion is made in good faith and not for the purpose of delay or any other

improper purpose.

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           Case 5:21-cv-00251-BO         Document 61    Filed 12/06/21     Page 1 of 3
       5.     Plaintiff requests additional time to respond to Defendants’ Discovery Requests

through and including January 10, 2022.

       6.     Pursuant to Local Rule 6.1(a), the undersigned certifies that she has consulted with

the counsel for Defendants, who consents to the extension of time.

       7.     A proposed order is submitted contemporaneously with the filing of this Motion.



RESPECTFULLY SUBMITTED this the 6th day of December, 2021.


                                            /s/ Beth A. Stanfield
                                            Beth A. Stanfield (N.C. State Bar No. 36296)
                                            Laura K. Greene (N.C. State Bar No. 47771)
                                            FORREST FIRM, P.C.
                                            105 Grace Street, Suite 101
                                            Wilmington, NC 28401
                                            T/F: (336) 275 - 6344
                                            Beth.stanfield@forrestfirm.com
                                            katie.greene@forrestfirm.com
                                            Attorneys for Plaintiff




                                               2

        Case 5:21-cv-00251-BO         Document 61       Filed 12/06/21      Page 2 of 3
                                CERTIFICATE OF SERVICE
       The undersigned attorney hereby certifies that the foregoing AMENDED MOTION FOR

EXTENSION OF TIME has been filed with the Clerk for the United States District Court,

Eastern District of North Carolina, using the electronic filing system of the Court. The electronic

case filing system will send a “Notice of Electronic Filing” to all attorneys of record who have

consented to accept service by electronic means.

       This the 6th day of December, 2021.
                                                            /s/ Beth A. Stanfield
                                                            Beth A Stanfield
                                                            Laura K. Greene

                                                            Attorneys for Plaintiff




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        Case 5:21-cv-00251-BO          Document 61       Filed 12/06/21      Page 3 of 3

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