Unopposed Motion for Extension of Time (2020-05-06)

Summary

Defendant's unopposed motion for extension of time to respond to complaint, Document 36 filed May 26, 2020, in 3M Company v. TAC2 Global LLC, Case No. 8:20-cv-1003-T-35CPT, in the United States District Court, Middle District of Florida, Tampa Division. It states that Defendant was served on May 6, 2020 and that the response to the Complaint is due May 27, 2020. The motion asks to extend that deadline for an additional week, or until June 3, 2020, and describes the complaint as an Eight Count complaint. A certificate of good faith states that Plaintiff's counsel agreed to the requested extension.

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Date: 2020-05-06

Cite this document

“Unopposed Motion for Extension of Time (2020-05-06).” Original at ecf.flmd.uscourts.gov, dated 2020-05-06. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-05-06-t-35cpt-v-tac2-global-llc/, SHA-256 4fb0ea673b288648331e4bc6363ec6f3f218d3d86ac20e322c0103fe276265cf.

Full text

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION

3M COMPANY

Plaintiff,

CASE NO. 8:20-cv-1003-T-35CPT
v.

TAC2 GLOBAL LLC

Defendant.

UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND TO COMPLAINT

Defendant, TAC2 GLOBAL, LLC (“TAC2” or “Defendant”), pursuant to Rule 6 of the Federal
Rules of Civil Procedure, by and through its undersigned counsel, hereby moves to extend the deadline to
respond to Plaintiff’s Complaint [D.E. 1]. In support of this motion, Defendant states the following:
1.
This is action consists of an Eight Count complaint asserting the following causes
of action: Violation of Florida’s Unfair and Deceptive Trade Practices Act (“FDUTPA”);
Trademark Infringement Under Fla. Stat. 495.131; Dilution under Fla. Stat. §495.151; Unfair
Competition under Florida Common Law; False Advertising Under the Lanham Act; Trademark
Infringement under the Lanham Act; Unfair Competition, False Endorsement, False Association,
and False Designation of Origin Under the Lanham Act; and Trademark Dilution under the
Lanham Act.
2.
Defendant was served with this lawsuit on May 6, 2020.
3.
Pursuant to Rule 12 of the Federal Rules of Civil Procedure, Defendant’s response to
Plaintiff’s Complaint is due on May 27, 2020.
Case 8:20-cv-01003-MSS-CPT Document 36 Filed 05/26/20 Page 1 of 3 PageID 408

4
Plaintiff filed a Motion for Temporary Restraining Order and Preliminary Injunction [D.E.
8] just five (5) days after Plaintiff’s Complaint was filed and served said motion on Defendant on May 8,
2020, requiring a response by May 22, 2020.
5.
Defendant’s counsel has prepared a response to Plaintiff’s Motion for Temporary
Restraining Order and Preliminary Injunction [D.E. 34] and is requesting a short extension just one (1) extra
week to prepare a response to Plaintiff’s Complaint as the Complaint involves numerous counts and
complex legal issues.
MEMORANDUM OF LAW
Federal Rule of Civil Procedure, Rule 6(b) provides that the Court may, for good cause extend the
time for an action upon motion of a party prior to the original deadline. As stated above, Plaintiff has
provided good cause to extend the deadline to respond to the Complaint due to the nature of the
issues involved and the necessity of responding to the Preliminary Injunction Motion. There will
be no prejudice to the Court or the parties if the Unopposed Motion is granted.
WHEREFORE, the Defendant’s counsel respectfully requests that this Court grant this Unopposed
Motion for Extension of Time to Respond to Complaint for an additional week, or until June 3, 2020, and
for any other relief as the Court may allow.

/s/ Amy E. Stoll

Amy E. Stoll, Esquire

Florida Bar No. 150959

Richard C. Alvarez, Esquire

Florida Bar No. 031615

Older Lundy & Alvarez

1000 West Cass Street

Tampa, Florida 33606

Phone: (813) 254-8998

Fax: (813) 839-4411

astoll@olalaw.com

jblanchette@olalaw.com

Case 8:20-cv-01003-MSS-CPT Document 36 Filed 05/26/20 Page 2 of 3 PageID 409

CERTIFICATE OF GOOD FAITH

DEFENDANT’S COUNSEL HEREBY CERTIFIES that it conferred with Plaintiff’s
counsel, in good faith and in accordance with Local Rule 3.01(g), and Plaintiff’s counsel agreed
to the requested extension.
CERTIFICATE OF SERVICE

DEFENDANT’S COUNSEL HEREBY CERTIFIES that on May 26, 2020, a true and
correct copy of this Motion was electronically filed with the Clerk of Court using the CM/ECF
system so that notice will be sent to all counsel of record.