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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

FORT PIERCE DIVISION 

Case No.: 2:20-CV-14159-ROSENBERG/MAYNARD 

DJ LINCOLN ENTERPRISES, INC., 

 Plaintiff, 

v. 

GOOGLE LLC 

 Defendant. 

UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT 

Defendant GOOGLE LLC (“Google”) respectfully moves for an unopposed extension of 

time until July 31, 2020, to file a response to Plaintiffs’ Complaint. In support of this unopposed 

motion, Google states: 

1. Plaintiffs filed their Complaint on May 21, 2020. 

2. Google was served with the Complaint on May 29, 2020. 

3. Absent an extension of time, Google’s response to the Complaint is due June 19, 2020. 

4. Google requests an extension up to, and including July 31, 2020, to respond to the 

Complaint. Counsel seeks this extension due to a previously planned vacation as well as 

commitments in other matters. The requested extension will permit counsel the time needed to 

adequately analyze the issues presented in the Complaint and determine how to appropriately 

respond. 

5. This is Google’s first motion to extend their deadline to respond to the Complaint. 

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6. This motion is made before the expiration of the periods prescribed by the Federal 

Rules of Civil Procedure and the Local Rules of Court, is made in good faith, is not sought for the 

purpose of delay, and will not prejudice any party. 

7. Counsel for Plaintiff DJ Lincoln Enterprise, Inc. advised it has no objection to the 

motion. 

MEMORANDUM OF LAW 

Rule 6(b) of the Federal Rules of Civil Procedure provides: 

When by . . . order of court an act is required or allowed to be done 

at or within a specified time, the court for cause shown may at any 

time in its discretion . . . with or without motion or notice order the 

period enlarged if request therefore is made before the expiration of 

the period originally prescribed or as extended by a previous order . 

. . 

Accordingly, Google respectfully requests this Court exercise its discretion and extend the 

deadline to respond to the Complaint until July 31, 2020. 

WHEREFORE, Google respectfully request that the Court enter an Order extending 

through and including July 31, 2020, Google’s deadline to file a response to the Complaint. 

CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(a)(3)

In accordance with Local Rule 7.1(a)(3), attorneys for Defendant certify that in good faith, 

before filing this motion, they conferred with counsel for Plaintiff regarding the relief sought 

herein, and counsel for Plaintiff advised that they do not object to the requested relief. 

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Dated: June 12, 2020 Respectfully submitted, 

/s/ Nathan M. Berman 

Nathan M. Berman 

FBN: 0329230 

nberman@zuckerman.com 

Zuckerman Spaeder LLP 

101 E. Kennedy Blvd., Suite 1200 

Tampa, Florida 33602 

813-221-1010 

813-223-7961 (Fax) 

Attorney for Defendant Google LLC 

CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that on June 12, 2020, I electronically filed the foregoing with the 

Clerk of Court by using the Court’s CM/ECF system thereby serving all registered users in this 

case. 

/s/Nathan M. Berman 

Nathan M. Berman 

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