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  • 111 - Motion For Extension of Time For Lisa's Reply

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    Lisa Borodkin, the defendant, filed a motion for a one-week extension of time to file a reply in support of her pending motion to dismiss the verified first amended complaint. She requested the extension due to her busy work schedule preparing for upcoming trials and hearings. The plaintiff's position on the extension was not provided. The extension would allow her to avoid prejudice to her clients or financial hardship and would not unduly delay the proceedings.

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    Pleadings filed in malicious prosecution action against attorney Lisa Borodkin.

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    111 - Motion for Extension of Time for Lisa's Reply

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    Lisa Borodkin, the defendant, filed a motion for a one-week extension of time to file a reply in support of her pending motion to dismiss the verified first amended complaint. She requested the extension due to her busy work schedule preparing for upcoming trials and hearings. The plaintiff's position on the extension was not provided. The extension would allow her to avoid prejudice to her clients or financial hardship and would not unduly delay the proceedings.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
    Flag for inappropriate content
    Download as pdf or txt
    92 views4 pages

    111 - Motion For Extension of Time For Lisa's Reply

    Uploaded by

    Ripoff Report
    Lisa Borodkin, the defendant, filed a motion for a one-week extension of time to file a reply in support of her pending motion to dismiss the verified first amended complaint. She requested the extension due to her busy work schedule preparing for upcoming trials and hearings. The plaintiff's position on the extension was not provided. The extension would allow her to avoid prejudice to her clients or financial hardship and would not unduly delay the proceedings.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as PDF, TXT or read online from Scribd
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    of 4

    Case 2:11-cv-01426-GMS Document 111 Filed 08/23/12 Page 1 of 4

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    Lisa J. Borodkin (CA Bar #196412) [email protected] 777 South Figueroa Street, 37th Floor Los Angeles, California 90017 Admitted Pro Hac Vice
    Firm State Bar No. 00443100 Renaissance One, Two North Central Ave. Phoenix, AZ 85004-2391
    TELEPHONE 602.229.5200

    Quarles & Brady LLP

    John S. Craiger (#021731) [email protected] David E. Funkhouser III (#022449) [email protected] Attorneys for Defendant Lisa Jean Borodkin IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA XCENTRIC VENTURES, L.L.C., Plaintiff, v. LISA JEAN BORODKIN and JOHN DOE BORODKIN, husband and wife; RAMOND MOBREZ and ILIANA LLANERAS, husband and wife; DANIEL BLACKERT and JANE DOE BLACKERT, husband and wife; ASIA ECONOMIC INSTITUTE, LLC, a California limited liability company, DOES 1-10, inclusive, Defendants. For the reasons identified below, Defendant Lisa Jean Borodkin (Ms. Borodkin) respectfully moves this Court for a brief extension of time, through and including August 30, 2012, by which she must file a Reply in support of her pending motion to dismiss the No. 2:11-CV-01426-PHX-GMS DEFENDANT LISA JEAN BORODKIN'S MOTION FOR EXTENSION OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO DISMISS UNDER RULE 12(b)6 (Assigned to the Honorable G. Murray Snow)

    QB\145800.00002\14782893.1

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    Case 2:11-cv-01426-GMS Document 111 Filed 08/23/12 Page 2 of 4

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    Verified First Amended Complaint under Federal Rule of Civil Procedure 12(b)(6) [Doc. 102] A proposed form of order is submitted herewith. Ms. Borodkin requests this extension in good faith due to the press of business serving clients in her practice. Among other things, she is preparing for a trial in San Diego Superior Court on September 10, 2012 and for a hearing on a motion in Los Angeles Superior Court on September 12, 2012. As she is appearing pro hac vice in this matter, she requests this extension so that neither her clients nor she will be prejudiced and to avert financial hardship. Ms. Borodkin has requested the Plaintiffs position on the extension and has not received an assent or an opposition. See Exh. A. No previous extension for filing this Reply has been requested. The requested one-week extension should not prejudice or unduly delay the Plaintiff. Ms. Borodkin is also working with the Plaintiff to coordinate compliance with the Court deadlines in the Case Management Order [Doc. 85], including seeking to schedule the mandatory in-person good faith settlement discussions that must occur by September 14, 2012. For the above reasons, Ms. Borodkin respectfully requests that the Court grant her an extension of time, through and including August 30, 2012, by which she must file her Reply. RESPECTFULLY SUBMITTED this 23rd day of August 2012.

    QB\145800.00002\14782893.1

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    Case 2:11-cv-01426-GMS Document 111 Filed 08/23/12 Page 3 of 4

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    By /s/ Lisa J. Borodkin Lisa J. Borodkin 777 South Figueroa Street 37th Floor Los Angeles, California 90017 Admitted Pro Hac Vice QUARLES & BRADY LLP Renaissance One, Two North Central Avenue Phoenix, AZ 85004-2391 John S. Craiger David E. Funkhouser III Attorneys for Lisa Jean Borodkin

    QB\145800.00002\14782893.1

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    Case 2:11-cv-01426-GMS Document 111 Filed 08/23/12 Page 4 of 4

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    CERTIFICATE OF SERVICE I hereby certify that on August 23, 2012, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing and transmittal of a Notice of Electronic Filing to the following CM/ECF registrant: David S. Gingras, Esq. ([email protected]) Attorneys for Plaintiff Raymond Mobrez ([email protected]) Pro se Iliana Llaneras ([email protected]) Pro Se /s/ Lisa J. Borodkin

    QB\145800.00002\14782893.1

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