UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 20-cv-23242-BLOOM/LOUIS

UNITED STATES OF AMERICA ex rel.

SEDONA PARTNERS, LLC,

Plaintiff,

v.

ABLE MOVING & STORAGE, INC.; ARPIN

VAN LINES, INC.; CARTWRIGHT

INTERNATIONAL VAN LINES, INC.;

COLEMAN AMERICAN MOVING SERVICES,

INC.; DEWITT COMPANIES LIMITED, LLC;

HILLDRUP COMPANIES, INC.; J.K. MOVING &

STORAGE INC.; MAYFLOWER TRANSIT, LLC;

NEW WORLD VAN LINES, INC.; PARAMOUNT

TRANSPORTATION SYSTEMS; PAXTON VAN

LINES, INC.; AND WESTERN EXPRESS

FORWARDING, LLC,

Defendants.

/

DEFENDANT, PARAMOUNT TRANSPORTATION SYSTEMS, INC.’s CONSENT

MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO COMPLAINT

COMES NOW the Defendant, PARAMOUNT TRANSPORTATION SYSTEMS, INC. 

(“Paramount”), by and through undersigned counsel and pursuant to Rule 6(b) of the Fed. R. Civ.

P., and hereby requests a brief extension of time to file its Response to the Complaint filed by 

SEDONA PARTNERS, LLC, and states: 

1. Plaintiff filed its Complaint on August 4, 2020 [D.E. 1].

2. Defendant was served with the Complaint on June 18, 2021. As such, the response to 

the Complaint is due on July 9, 2021.

3. The undersigned counsel was recently appointed and is on leave next week. Due to the 

complex nature of this case, including the underlying complaint and the number of 

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parties involved, Defendant would request a brief extension of time in order to properly 

evaluate the defenses1 and formulate a response to the complaint.

4. The requested extension is made in good faith and not for purposes of delay.

5. The undersigned has conferred with counsel for Plaintiff who consents to the relief 

requested herein.

6. Accordingly, good cause exists to grant the requested extension of time and no party 

will be prejudiced if the requested extension is granted.

7. Wherefore, Defendant would ask for a thirty (30) day extension to respond to the 

Complaint, up to and including August 9, 2021.

8. A proposed Order granting the instant Motion is attached hereto. The undersigned 

certifies that the instant Motion complies with the Local Rules and the Court’s Orders.

S.D. FLA. LOCAL RULE 7.1 (A)(3) CERTIFICATION

Counsel for Defendant has conferred email with counsel for Plaintiff who consents to the 

relief requested herein.

Dated: July 1, 2021 Respectfully Submitted,

SPECTOR RUBIN, P.A.

By: /s/ Robert M.Borak

Robert M. Borak (FBN 015923)

Andrew R. Spector (FBN 634093)

3250 Mary Street, Suite 405

Miami, Florida 33133

Tel: 305.537.2000

Fax: 305.537.2001

Robert.Borak@spectorrubin.com

Andrew.Spector@spectorrubin.com

Counsel for Defendant, Paramount

Transportation Systems, Inc.

1 In submitting the instant motion, Defendant expressly preserves all objections and defenses related to venue, and 

personal jurisdiction. 

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CERTIFICATE OF SERVICE

WE HEREBY CERTIFY that on July 1, 2021, a true and correct copy of the foregoing was 

filed with the Clerk of Court via the Court’s CM/ECF system, which shall serve a copy of same 

upon all counsel of record.

SPECTOR RUBIN, P.A.

/s/ Robert M.Borak

Robert M. Borak (FBN 015923)

Andrew R. Spector (FBN 634093)

Case 1:20-cv-23242-BB Document 49 Entered on FLSD Docket 07/01/2021 Page 3 of 3