UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT or FLORIDA

No.09:11-cv-80880-KLR
QSGI, Inc., a Delaware Corporation,
Plaintiff,
v.
IBM GLOBAL FINANCING, a Division of
International Business Machines Corp., and
INTERNATIONAL BUSINESS MACHINES
CORP., Parent to andlor d/bla IBM GLOBAL
FINANCING,
Defendants.
_______________________________ 1
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE
EXPERT WITNESS DISCLOSURES
Plaintiff, by and through undersigned counsel, hereby files this Motion for Extension of
Time to File Expert Witness Disclosures. In support thereo f, Plaintiff states as follows:
1. Plaintiff's Expert Witness Disclosure is due \fay 1,2012.
2. Due to the voluminous amount of document, provided by Defendants in response
to Plaintiff s Request for Production, Plaintiff has not beell able to determine what experts may
be used at trial.
3. Plaintiff has reached out to counsel for Defendants via electronic mail requesting
a ten (10) day extension of time to file their Expert Disclosure but as of the filing of this
Motion, no response has been received.
WHEREFORE, Plaintiff respectfully requests this Court grant Plaintiffs Motion for
Extension of Time to file its Expert Witness Disclosures.
Case 9:11-cv-80880-KLR Document 67 Entered on FLSD Docket 05/01/2012 Page 1 of 2
By:
Respec',fully submitted,
THE FERRARO LAW FIRM, P.A.
Attornevs for the Plaintiff
4000 Ponce de Leon Blvd.
Suite 71)0
Miami, FL 33146
Telephone (305) 375-0111
Facsimile (305) 379-6222
Email: cxd@ferrarolaw.com
lsI Juar: P. Bauta, II
JUAN P. BAUTA, II, ESQ.
Florida Bar No. 894060
CASE <\. DAM, ESQ.
Florida Bar No. 756091
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the j ore going was served via CMIECF on
all counsel of record this 1st day of May 2012.
lsI Juan P. Bauta, II
By: ___ ::--:-:-:=-:-----:-:-=:::-::--__
JUAN P. BAUTA, II, ESQ.
Florida Bar No. 894060
2
Case 9:11-cv-80880-KLR Document 67 Entered on FLSD Docket 05/01/2012 Page 2 of 2
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO: 11-80880-CIV-RYSKAMP\vITUNAC
QSGI, Inc., a Delaware Corporation,
Plaintiff,
v.
IBM GLOBAL FINANCING, et al.
Defendants.
______________________________ ~ I
ORDER GRANTING PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE
EXPERT WITNESS DISCLOSURES
THIS CAUSE having come before the Court on Plaintiffs Motion for Extension of Time
to File Expert Witness Disclosures and the Court having considered Plaintiffs Motion and being
fully advised in the premises, it is hereupon:
ORDERED AND ADJUDGED:
1. Plaintiffs Motion is GRANTED.
2. Plaintiff shall file its Expert Witness Disclosures ,m or before May 11, 2012.
DONE AND ORDERED in Chambers at West Palm B,)ach, Florida, this ___ day of
_____________________ , 2012.
KENNETH L. RYSKAMP
UNITED STATES DISTRICT JUDGE
Case 9:11-cv-80880-KLR Document 67-1 Entered on FLSD Docket 05/01/2012 Page 1 of 1