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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’ 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 is 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.

4. Undersigned counsel for PARAMOUNT attempted to confer with Plaintiff’s 

counsel regarding this Motion, but did not receive a response before this Motion was filed.

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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 

District of Florida, the undersigned certifies:

[ ] that he has conferred with Plaintiff’s counselwho 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. Undersigned counsel sent an email to plaintiff’s counsel at 2:24 

p.m. on October 3, 2022, but received no response before close of business.

Dated the 3

rd day of October, 2022. Respectfully submitted,

PARAMOUNT RECOVERY SYSTEMS, 

L.P.

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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 3

rd 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

Counsel for Plaintiff

s/ Hector E. Lora

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