UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION

Civil Action No. 0:20-cv-61321-WPD

DAVID “RYAN” McCAIGUE, an individual,

Plaintiff,

vs.

DOENCH WEALTH MANAGEMENT, LLC; 

and BRIAN H. DOENCH, an individual,

Defendants.

______________________________________/

DEFENDANTS’ UNOPPOSED MOTION FOR 

ENLARGEMENT OF TIME TO RESPOND TO COMPLAINT

Defendants Doench Wealth Management, LLC and Brian H. Doench (collectively, 

“Defendants”), hereby respectfully move the Court for entry of an unopposed Order granting a 

thirty (30) day enlargement of time for Defendants to serve their responses to the Complaint filed 

by Plaintiff David “Ryan” McCaigue, and in support state as follows:

1. On July 1, 2020, Plaintiff David “Ryan” McCaigue filed a Complaint (the 

“Complaint”) bearing the above caption and assigned the case number 0:20-cv-61321, against 

Defendants. [D.E. 1]. 

2. On July 6, 2020, Defendants were served with the Complaint. 

3. Pursuant to Federal Rules of Civil Procedure 12(a)(1)(A)(i) and 6(a), Defendants’

responses to the Complaint are currently due Monday, July 27, 2020. 

4. Defendants seek a thirty (30) day enlargement of time, through and including 

Wednesday, August 26, 2020, to respond to the Complaint.

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5. Defendants and their counsel seek the additional time due to their recent 

engagement in the matter and in order to adequately investigate the claims and factual allegations 

in the Complaint and to prepare the responses. 

6. Counsel for Defendants has conferred with Plaintiff’s counsel; this Motion is not 

opposed.

7. This Motion is made in good faith and not for purposes of delaying the ultimate 

resolution of this case.

Memorandum of Law

Rule 6(b) of the Federal Rules of Civil Procedure provides that this Court has the 

discretion to enlarge any time prescribed by the federal rules, local rules, or court order. Here, 

Defendants are seeking an unopposed enlargement of time to respond to the Complaint before 

their time period to respond has expired. Since this extension of time is sought in good faith, not 

for any purposes of delay, and is requested for the preparation of responses to the Complaint, 

Defendants respectfully request that the Court grant their request for an enlargement of time.

WHEREFORE, Defendants respectfully request a thirty (30) day enlargement of time 

through and including Wednesday, August 26, 2020 in which to serve responses to Plaintiff 

David “Ryan” McCaigue’s Complaint.

Certificate of Compliance with Local Rule 7.1(a)(3)

Counsel for Defendants hereby certify that they have conferred with counsel for Plaintiff 

David “Ryan” McCaigue prior to the filing of this Motion and that counsel does not oppose the 

relief requested by this Motion.

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Dated: July 22, 2020 MCGUIREWOODS LLP

By: /s/ Kimberly T. Mydock 

 Kimberly T. Mydock (FL Bar No. 100571)

 kmydock@mcguirewoods.com

 50 North Laura Street, Suite 3300

 Jacksonville, FL 32202-3661

 Telephone: 904-798-3200

 Facsimile: 904-798-3207

Larissa LPC Sneathern (pro hac vice forthcoming)

 lsneathern@mcguirewoods.com

 652 Peter Jefferson Parkway

 Suite 350

 Charlottesville, VA 22911

 Telephone: 434-977-2593

 Facsimile: 434-980-2222

Attorneys and Trial Counsel for Defendants Doench 

Wealth Management, LLC and Brian H. Doench

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 22, 2020, I electronically filed the foregoing with the 

Clerk of the Court by using the CM/ECF system which will send a notice of electronic filing to 

the following:

David Silver, Esq.

D.Silver@SilverMillerLaw.com

11780 W. Sample Road

Coral Springs, Florida 33066

Attorney for Plaintiff David “Ryan” McCaigue

/s/ Kimberly T. Mydock 

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