UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

I-O-T-L, INC. 

Plaintiff, 

v. 

STARR SURPLUS LINES INSURANCE 

COMPANY 

Defendant. 

Civil Action No. 2:20-cv-14216-RLR

 

JOINT MOTION FOR EXTENSION OF TIME TO FILE 

JOINT SCHEDULING REPORT 

Plaintiff, I-O-T-L-, INC., and defendant, Starr Surplus Lines Insurance Company, by and 

through their respective undersigned counsel and pursuant to Federal Rule of Civil Procedure 

6(b), hereby file the following joint motion for extension of time to file a joint scheduling report, 

and state as follows: 

1. On June 29, 2020, I-O-T-L filed the instant lawsuit in this Court pursuant to 

28 U.S.C. § 1332 (ECF No. 1). 

1. On July 13, 2020, the Court entered an Order requiring the Parties to file a joint 

scheduling report “[w]ithin two weeks of (1) the date upon which any one defendant appears in 

this action or (2) the rendition of this Order, whichever is later.” (ECF No. 7). 

2. On July 21, 2020, Starr appeared in this action and filed a Motion to Dismiss 

based on forum non conveniens. (EFC No. 9). 

3. The joint scheduling report is therefore due on August 4, 2020. 

4. Federal Rule of Civil Procedure 6(b)(1) provides that “[w]hen an act may or must 

be done within a specified time, the court may, for good cause, extend the time: (A) with or 

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without motion or notice if the court acts, or if a request is made, before the original time or its 

extension expires. . . .” 

5. In light of Starr’s pending motion to dismiss, which may obviate the need for 

further litigation before this Court, the parties believe that a brief extension of the deadline to file 

a joint scheduling report would serve the interests of the parties and the Court by promoting 

judicial efficiency and conserving time and resources. 

6. The Parties therefore respectfully request an extension of time by which to file 

their joint scheduling report, to ten days following a decision on Starr’s Motion to Dismiss. 

7. The Parties submit that good cause exists for this extension, and that the relief 

requested will not affect any other deadline set forth in the Court’s July 13, 2020 Order. 

8. Furthermore, this motion is being made in good faith and not for any undue 

purpose of delay. 

WHEREFORE, I-O-T-L, INC. and Starr Surplus Lines Insurance Company 

respectfully request an extension to file a joint scheduling report in the instant matter, to ten days

following the Court’s decision on Starr’s Motion to Dismiss. 

 

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CERTIFICATE OF GOOD FAITH CONFERENCE 

Pursuant to Local Rule 7.1(a)(3), the Parties certify that they conferred with respect to the 

matters addressed herein and file this motion jointly. 

Respectfully submitted, 

HARTLEY LAW OFFICES, PLC 

/s/ Timothy M. Hartley 

Timothy M. Hartley, Esq. (Fla. Bar No. 

979066) 

12 SE Seventh Street, Suite 610 

Fort Lauderdale, Florida 33301 

Tel. (954) 357-9973 

Fax. (954) 357-2275 

hartley@hartleylaw.net 

Counsel for Plaintiff 

MOUND COTTON WOLLAN & 

GREENGRASS LLP 

/s/ Perry R. Goodman __ 

Perry R. Goodman, Esq. (Fla. Bar No. 50778) 

110 E. Broward Blvd., Suite 1580 

Fort Lauderdale, FL 33301 

Tel. (954) 467-5800 

Fax (954) 467-5880 

pgoodman@moundcotton.com 

Costantino P. Suriano, Esq. (pro hac vice 

forthcoming) 

Samuel B. Weiss, Esq. (pro hac vice 

forthcoming) 

One New York Plaza, 44th Floor 

New York, NY 10004 

csuriano@moundcotton.com

sweiss@moundcotton.com

Tel. (212) 804-4200 

Fax (212) 344-8066 

Counsel for Defendant 

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CERTIFICATE OF SERVICE 

 I hereby certify that on July 23, 2020, the foregoing document was electronically filed 

with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being 

served this day on all counsel of record identified on the below Service List via transmission of 

Notices of Electronic Filing generated by CM/ECF: 

 By: /s/ Perry R. Goodman 

Perry R. Goodman, Esq. (Fla. Bar No. 50778) 

pgoodman@moundcotton.com

 

SERVICE LIST 

Timothy Maze Hartley, Esq. 

Hartley Law Offices, PLC 

12 SE Seventh Street 

Suite 610 

Fort Lauderdale, FL 33301 

954-357-9973 

Fax: 954-357-2275 

Email: hartley@hartleylaw.net 

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