Opinion
CIVIL NO. 2:11cv00115
08-14-2011
EDUARDO D. LIBRES, an individual, Plaintiff, v. BANK OF AMERICA, a Business Entity, form unknown,; COUNTRYWIDE HOME LOANS, INC., a Business Entity, form unknown; LR FINANCIAL, LLC /DBA/ SOUTHERN NEVADA MORTGAGE, a Business Entity, form unknown; LAWYERS TITLE OF NEVADA, INC, a Business Entity, form unknown; MORTAGE ELECTRONIC REGISTRATION SYSTEMS, INC., a Business Entity, form unknown; and DOES 1-100 inclusive. Defendants,
Zachary T. Ball, Esq. Nevada Bar No. 8364 Attorneys for Defendant Lawyers Title of Nevada, Inc. ARIEL E. STERN Nevada Bar No. 8276 JACOB D. BUNDICK Nevada Bar No. 9772 DIANA S. ERB Nevada Bar No. 10580 AKERMAN SENTERFITT, LLP
Eduardo Libres
MOTION TO REQUEST ENLARGEMNET OF TIME FOR FILING SHOW A GOOD
CAUSE OF WHY THIS CASE SHOULD NOT BE DISMISS UNDER THE RULE 6fB)
AND TO ALLOW PLAINTIFF A DISCOVERY PURSUANT TO RULE 26
MOTION TO REQUEST ENLARGEMENT OF TIME FOR FILING SHOW A GOOD
CAUSE OF WHY THIS CASE SHOULD NOT BE DISMISS UNDER THE RULE 6(B)
AND TO ALLOW PLAINTIFF A DISCOVERY PURSUANT TO RULE 26
Plaintiffs' respectfully move this case to enlargement of time for filing a good cause on why this case should not be dismiss and to allow Plaintiff a discovery for the reasons set forth below;
1. Plaintiff do not have access to a large staff to handle like an ordinary business, let alone the extra-ordinary demands of litigation. Plaintiff is a PRO SE litigant and have been preparing the documents slowly and have been carefully assigned to assure Plaintiff's orderly and timely involvement with this case and answer to be going to file will be carefully fit and valid.
2. Federal Defendant' conducts has forced Plaintiff to represent his imminently threatened agency action. Plaintiffs felt stressed and cannot concentrate and deprived his ability to prepare and file any documents to be answer within the time normally allotted for the same as a lawyer.
3. Plaintiffs' believe an extension of time to show a good cause of why this case should not be dismiss would be sufficient for filing an extension of time to August 11, 2011.
WHEREFORE, Plaintiffs move this Court for an Order extending the time for filing show good cause of why this case should not be dismiss and to allow discovery against the defendants' and Enlargement of time to August 11, 2011 pursuant to FCRP 16(b).
Eduardo Libres
PRO SE PLAINTIFF
CERTIFCATE OF SERVICE
I HEREBY CERTIFY THAT ON THIS DATE, A TRUE AND CORRECT COPIES OF
THE FOREGOING DOCUMENT WAS SERVED ON THE FOLLOWING BY U.S.
CERTIFIED MAIL TO DEFENDANT'S ATTORNEYS NOTED BELOW;
Defendant Attorneys:
Zachary T. Ball, Esq.
Nevada Bar No. 8364
Attorneys for Defendant Lawyers Title of
Nevada, Inc.
ARIEL E. STERN
Nevada Bar No. 8276
JACOB D. BUNDICK
Nevada Bar No. 9772
DIANA S. ERB
Nevada Bar No. 10580
AKERMAN SENTERFITT, LLP
IT IS ORDERED tha plaintiff's motion (#23) is denied without prejudice.
Lawrence R. Leavitt
U.S. Magistrate Judge
Eduardo D. Libres,
Plaintiff Pro Se