Page 1 of 4

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

WEST PALM BEACH DIVISION

JAMES BRANDON, CASE NO.: 9:22-cv-81327 

Plaintiff,

v.

PARAMOUNT RECOVERY SYSTEMS, L.P.;

HEALTHCARE REVENUE RECOVERY GROUP, LLC;

EQUIFAX INFORMATION SERVICES, LLC;

EXPERIAN INFORMATION SOLUTIONS, INC.; and

TRANSUNION LLC, 

Defendants.

______________________________________________/

DEFENDANT PARAMOUNT RECOVERY SYSTEMS’AMENDED MOTION FOR 

EXTENSION OF TIME TO RESPOND TO COMPLAINT

Defendant, PARAMOUNT RECOVERY SYSTEMS, L.P. (“PARAMOUNT”), by its 

counsel, moves pursuant to Fed. R. Civ. P. 6(b) for an extension of time to file its response to 

Plaintiff’s Complaint and in support states as follows: 

1. This is an action alleging that PARAMOUNT violated the federal Fair Credit 

Reporting Act (“FCRA”) and the federal Fair Debt Collection Practices Act (“FDCPA”). 

2. PARAMOUNT was served with process on September 12, 2022 through its 

Registered Agent, which means its response to the Complaint was due by October 3, 2022.

3. PARAMOUNT requires additional time to investigate the facts alleged in the 

Complaint to determine the validity of the claims raised in the Complaint and to respond to the 

Complaint for the following reasons: the attorney who is the point-of-contact with the client, 

PARAMOUNT, a resident of the State of Texas who is not admitted to the Bar of this Court, has 

been dealing with illness and a heavy workload, coupled with communication issues with the 

Case 9:22-cv-81327-DMM Document 15 Entered on FLSD Docket 10/07/2022 Page 1 of 4
Page 2 of 4

client, which prevented him from contacting his partner, local undersigned counsel, until the 

morning of October 3rd, when PARAMOUNT’S response to the Complaint was due. Undersigned 

counsel sent an email to Plaintiff’s counsel local counsel, Trescot Gear of Gear Law, LLC in an 

attempt to confer regarding whether he objected to the requested brief first extension of time. 

Undersigned counsel acknowledges that he should have tried to reach Plaintiff’s counsel by 

telephone, but simply got side-tracked with other work and did not do so inadvertently. 

4. Undersigned counsel waited until close of business on October 3rd and filed the first 

Motion for Extension of Time on 5:15 p.m. Thus, the Motion was not, with all due respect to this 

Court, “late filed” in the sense of being filed past the deadline to respond. The following day, 

October 4th at 12 Noon, undersigned counsel received an email from an attorney named Michael 

D. Adams from McCarthy Law, PLC in Scottsdale, Arizona, stating they “do not oppose the 10 

day extension.” This law firm is listed as Plaintiff’s counsel on page 19 of the Complaint along 

with Gear Law, LLC of Tampa.

Memorandum of Law

5. Pursuant to Federal Rule of Civil Procedure 6(b), the Court for cause shown may, 

in its discretion, order an enlargement of time if request is made before the expiration of the period 

originally prescribed or, upon motion made after the expiration of the specified period permit the 

act to be done where the failure to act was the result of excusable neglect.

WHEREFORE, PARAMOUNT RECOVERY SYSTEMS, L.P., requests that this Court

enter an Order enlarging the deadline for it to serve its response to the Complaint up to and 

including October 13, 2022.

Local Rule 7.1(a)(3) Certification

Pursuant to Local Rule 7.1(a)(3) of the United States District Court for the Southern 

Case 9:22-cv-81327-DMM Document 15 Entered on FLSD Docket 10/07/2022 Page 2 of 4
Page 3 of 4

District of Florida, the undersigned certifies:

[ √ ] that he has conferred with Plaintiff’s counsel who does not object to the relief 

requested in this motion.

[ ] that counsel for the movant has conferred with all parties or non-parties who may 

be affected by the relief sought in the motion in a good faith effort to resolve the issues raised in 

the motion and has been unable to do so. 

[ ] that counsel for the movant has made reasonable efforts to confer with all parties 

or non-parties who may be affected by the relief sought in the motion, which efforts shall be 

identified with specificity in the statement (including the date, time, and manner of each effort), 

but has been unable to do so. 

Dated the 7

th day of October, 2022. Respectfully submitted,

PARAMOUNT RECOVERY SYSTEMS, 

L.P.

By: /s/ Hector E. Lora

Hector E. Lora, Esq.

Florida Bar No. 755842

MAURICE WUTSCHER LLP

1801 N.E. 123rd Street, Suite 314

North Miami, FL 33181

Direct: (786) 553-8082

Fax: (866) 581-9302

E-mail: hlora@mauricewutscher.com and 

litigation@mauricewutscher.com

Certificate of Service

I CERTIFY that on the 7

th day of October, 2022, a copy hereof was served on the 

following interested parties via CM/ECF:

Trescot Gear, Esq.

McCarthy Law PLC

4250 North Drinkwater Blvd., Suite 320

Scottsdale, AZ 85281

E-mail: trescotgear@gmail.com

Case 9:22-cv-81327-DMM Document 15 Entered on FLSD Docket 10/07/2022 Page 3 of 4
Page 4 of 4

Counsel for Plaintiff

s/ Hector E. Lora

Case 9:22-cv-81327-DMM Document 15 Entered on FLSD Docket 10/07/2022 Page 4 of 4