On May 06, 2009 a
Motion,Ex Parte
was filed
involving a dispute between
A M E Manufacturing Corp,
J & J Refrigeration Supply Inc,
Warehouse 1050 Corp,
and
City Of Mia,
Comcast Cable Communications Etc,
Comcast Cable Communications Holdings Et,
Comcast Cable Holdings Llc,
Florida Power & Light Co,
Florida Sol Corp,
Florida Sol Systems Inc,
Miami Dade County,
State Of Fla,
Williams, Walter J,
for Other Civil Complaint
in the District Court of Miami-Dade County.
Preview
WAREHOUSE 1050 CORP.,
J AND J REFRIGERATION SUPPLY,
INC., and AME MANUFACTURING
CORP.,
Plaintiffs,
vs.
WALTER J. WILLIAMS, FLORIDA SOL
CORP. COMCAST CABLE
COMMUNICATIONS HOLDINGS, INC.,
COMCAST CABLE HOLDINGS, LLC,
FLORIDA POWER & LIGHT COMPANY,
STATE OF FLORIDA, CITY OF MIAMI,
MIAMI-DADE COUNTY, AND JOHN &
JANE DOES 1-100.
Defendants.
IN THE CIRCUIT OF THE 11™ JUDICIAL
CIRCUIT, IN AND FOR MIAMI-DADE
COUNTY, FLORIDA
CASE NO.: 09-36802 CA 11
FLORIDA BAR NO.: 0622508 ~ 3
z=
a
‘
>
=
No)
wn
wo
quogae 404 gata
©
i
4
Qo ¢
PLAINTIFFS’ SECOND MOTION FOR AN EXTENSION OF TIME FILE A FOURTH
AMENDED COMPLAINT
Plaintiffs, WAREHOUSE 1050 CORP., J AND J REFRIGERATION SUPPLY,
INC., and AME MANUFACTURING CORP (hereinafter “Plaintiffs”), by and through undersigned
counsel and pursuant to the Florida Rules of Civil Procedure, hereby move this Honorable Court for
hereby move this Honorable Court for the entry of an Order Extending the Time to File A Fourth
Amended Complaint and as grounds thereof state as follows:
1.
Fourth Amended Complaint.
Due to two trials and other unrelated matters, Plaintiff has been unable to file its3. Plaintiff requests an extension of time of fifteen (15) days in which to file a Fourth
Amended Complaint.
4. This matter is not set for trial and Defendants will not be prejudiced by the extension
of time sought.
WHEREFORE, Plaintiff respectfully requests this Honorable Court for the entry of an Order
extending the time in which to file a Fourth Amended Complaint and for other relief this court
deems just and proper.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 27th
day of July, 2011 to All parties listed on the attached Service List.
POMERANZ & ASSOCIATES, P.A.
1920 East Hallandale Beach Boulevard, Suite 802
Hallandale, Florida 33009
(305) 891-5858
L. POMERANZ
ORIDA BAR NO. 0622508
(OV bo7VIg,SERVICE LIST
Warren R. Bittner, Esq.
Deputy City Attorney
Attorneys for City of Miami
444 S.W. 2° Avenue
Suite 945
Miami, Florida 33130
[Fax: 305-416-1801]
Thomas W. Logue, Esquire
Assistant County Attorney
Attorneys for Miami-Dade County
111 N.W. 1% Street, Suite 2810
Miami, Florida 33128
[Fax: 305-375-5634]
Ryan G. Prescott, Esquire
Moore Ingram Johnson & Steele, L.L.P.
Attorneys for Comcast of Miami, Inc.
Emerson Overlook
326 Roswell Street
Marietta, GA 30060
[Fax: 1-770-429-8631]
Luis Perez, Esquire
Perez, Goran & Rodriguez
Attorneys for Florida Sol Corp
95 Merrick Way, Suite 610
Coral Gables, FL 33134
(Fax: i)
Steven J. Lachterman, Esquire
Attorneys for Florida Sol Corp
848 Brickell Avenue, Suite 750
Miami, Florida 33131
[Fax: 305-445-2735]
Document Filed Date
August 01, 2011
Case Filing Date
May 06, 2009
Category
Other Civil Complaint
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
WAREHOUSE 1050 CORP., J AND J REFRIGERATION SUPPLY, INC., and AME MANUFACTURING CORP., Plaintiffs, vs. WALTER J. WILLIAMS, FLORIDA SOL CORP. COMCAST CABLE COMMUNICATIONS HOLDINGS, INC., COMCAST CABLE HOLDINGS, LLC, FLORIDA POWER & LIGHT COMPANY, STATE OF FLORIDA, CITY OF MIAMI, MIAMI-DADE COUNTY, AND JOHN & JANE DOES 1-100. Defendants. IN THE CIRCUIT OF THE 11™ JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO.: 09-36802 CA 11 FLORIDA BAR NO.: 0622508 ~ 3 z= a ‘ > = No) wn wo quogae 404 gata © i 4 Qo ¢ PLAINTIFFS’ SECOND MOTION FOR AN EXTENSION OF TIME FILE A FOURTH AMENDED COMPLAINT Plaintiffs, WAREHOUSE 1050 CORP., J AND J REFRIGERATION SUPPLY, INC., and AME MANUFACTURING CORP (hereinafter “Plaintiffs”), by and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby move this Honorable Court for hereby move this Honorable Court for the entry of an Order Extending the Time to File A Fourth Amended Complaint and as grounds thereof state as follows: 1. Fourth Amended Complaint. Due to two trials and other unrelated matters, Plaintiff has been unable to file its3. Plaintiff requests an extension of time of fifteen (15) days in which to file a Fourth Amended Complaint. 4. This matter is not set for trial and Defendants will not be prejudiced by the extension of time sought. WHEREFORE, Plaintiff respectfully requests this Honorable Court for the entry of an Order extending the time in which to file a Fourth Amended Complaint and for other relief this court deems just and proper. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing was mailed this 27th day of July, 2011 to All parties listed on the attached Service List. POMERANZ & ASSOCIATES, P.A. 1920 East Hallandale Beach Boulevard, Suite 802 Hallandale, Florida 33009 (305) 891-5858 L. POMERANZ ORIDA BAR NO. 0622508 (OV bo7VIg,SERVICE LIST Warren R. Bittner, Esq. Deputy City Attorney Attorneys for City of Miami 444 S.W. 2° Avenue Suite 945 Miami, Florida 33130 [Fax: 305-416-1801] Thomas W. Logue, Esquire Assistant County Attorney Attorneys for Miami-Dade County 111 N.W. 1% Street, Suite 2810 Miami, Florida 33128 [Fax: 305-375-5634] Ryan G. Prescott, Esquire Moore Ingram Johnson & Steele, L.L.P. Attorneys for Comcast of Miami, Inc. Emerson Overlook 326 Roswell Street Marietta, GA 30060 [Fax: 1-770-429-8631] Luis Perez, Esquire Perez, Goran & Rodriguez Attorneys for Florida Sol Corp 95 Merrick Way, Suite 610 Coral Gables, FL 33134 (Fax: i) Steven J. Lachterman, Esquire Attorneys for Florida Sol Corp 848 Brickell Avenue, Suite 750 Miami, Florida 33131 [Fax: 305-445-2735]