Raanan Katz, Miami Heat, RK Centers Owner, Is Begging The Court For Extension Of Time

"Работать надо больше, а жрать меньше"

Raanan Katz, Miami Heat and RK Centers Owner, is begging the court for second extension of time. Raanan Katz filed his frivolous copyright case in Miami in June 12, 2012. Since that time Mr. Katz is requesting second extension of time. First motion for extension was filed in July, now in August Raanan Katz is looking for more time to delay the "case".

Yeah, Raanan Katz, it is not easy to handle your own "brilliant" abusive litigation practice!!! Probably Mr.Katz needs to hire third law firm to be able to meet court deadlines. Go Raanan Katz, GO...  Below is Raanan Katz motion.

RAANAN KATZ'S FIRST MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANT'S SECOND MOTION TO DISMISS
Plaintiff, Raanan Katz, by and through his undersigned counsel, hereby moves for an extension of time to respond to Defendant's Motion to Dismiss the Amended Complaint [the "Second Motion to Dismiss," DE 14], and states:
1.    The current deadline to respond to the Second Motion to Dismiss is August 27, 2012.
2.    Undersigned counsel (Michael B. Chesal) has just returned on the afternoon of August 2 from a two and one half week trip out of the country.
 3.    Defendant's Second Motion to Dismiss with its attached Exhibits exceeds over 200 pages and seeks dismissal of the Amended Complaint with prejudice. Plaintiff's counsel is preparing a substantive response but will need additional time given the nature of the motion coupled with being out of the office when the motion was served.
4.    Undersigned counsel is only seeking a ten (10) day extension of time to respond, up to and including September 6, 2012 in order to adequately respond to Defendant's Second Motion to Dismiss.
5.    This request is made in good faith and not for purposes of undue delay and will not unduly prejudice any of the parties involved in this action.
6.    In accordance with Local Rule 7.1(a)(3)(A), counsel for the movant certifies he has conferred with counsel for the Defendant in a good faith effort to resolve the issues raised in this motion but has been unable to do so. For some reason, counsel for the Defendant refuses to agree to the brief requested extension (even though undersigned counsel previously consented to an extension of time requested by Defendant's counsel, my comment: what extension Raanan Katz is talking about, his first one from July???). 7.    A proposed order granting the requested relief is submitted herewith. WHEREFORE, Plaintiff respectfully requests that the deadline to respond to Defendant's Second Motion to Dismiss be extended to September 6, 2012.

Dated: August 24, 2012

 Respectfully submitted,
KLUGER KAPLAN SILVERMAN KATZEN & LEVINE, P.L.
Co-Counsel for Raanan Katz
201 South Biscayne Blvd., 17th Floor
Miami, Florida 33131
Telephone: 305-379-9000
Facsimile: 305- 379-3428
By: /s Alan J. Kluger
Alan J. Kluger
Florida Bar No. 200379
Email: akluger@ klugerkaplan.com
Todd A. Levine
Florida Bar No. 899119
Email: tlevineklugerkaplan.com
and

PERETZ CHESAL & HERRMANN, P.L. Co-Counsel for Raanan Katz
201 South Biscayne Blvd., Suite 1750 Miami, Florida 33131
Telephone: 305-341-3000
Facsimile: 305-371-6807
By: /s Michael B. Chesal
Michael B. Chesal
Florida Bar No. 775398
Email: mchesal@pch-iplaw.com
Josh E. Saltz
Florida Bar No. 70521
Email: jsaltz@pch-iplaw.com