Case 9:11-cv-80880-KLR Document 91 Entered on FLSD Docket 06/12/2012 Page 1 of 2

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OI? FLORIDA

Case No. 09:11-cv-SOSNO-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 and/or d/b/a IBM GLOBAL FINANCING Defendants.

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PLAINTIFF'S RENEWED MOTION FOR EXTENSION OF TIME TO FILE EXPERT WITNESS DISCLOSURES 1

Plaintiff, QSGI, INC., CQSGI"), by and through unjersigned counsel, files this Renewed Motion for Extension of Time to File Expert Witness Discl(,sure and in support thereof states: I. Pursuant to the parties' agreement, Plaintiffs Expert Witness Disclosure is due June 12,2012. 2. Due to the voluminous amount of documents provded to Defendants in response to Plaintiffs Request for Production, Plaintiff still is determining what experts may be used at trial. Additionally, given the voluminous amount of documents Jfoduced by both sides, the potential experts require additional time to review the materials.

1 Plaintiff originally filed a motion for extension with respect to expert witness disclosures on May I. 2012. [D.E.#67] Thereafter, Defendants' counsel stated such a motion was wt necessary because the parties had agreed that expert witness disclosures would be made on June 12,2012. Aw"dingly, Plaintiff did not pursue its original

motion.

Case 9:11-cv-80880-KLR Document 91 Entered on FLSD Docket 06/12/2012 Page 2 of 2

3.

Moreover, fact discovery in this case, includmg addressing the many discovery

motions filed, has consumed significantly more time than anticipated at the beginning ofthis case. 4. Plaintiff reached out to counsel for Defendants via telephone and electronic mail requesting a thirty (30) day extension of time to file its Expert Witness Disclosure and Defendants object to the Motion. 2 WHEREFORE, Plaintiff respectfully requests this Court grant Plaintiffs Motion for Extension of Time to file its Expert Witness Disclosures. Respectfully submitted, THE FERRARO LAW FIRM, P.A. Attorneys for the Plaintiff 4000 PClnce de Leon Blvd., Suite 700 Miami, FL 33146 Telephcne (305) 375-0111 Facsimile (305) 379-6222

lsi Juan P. Bauta, II

By: JUAN 1'. BAUTA, II, ESQ. Florida Bar No. 894060 MELISSA DAMIAN VISCONTI, ESQ. Florida Bar No. 0068063

CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing was served via CMlECF on all counsel of record this 12th day of June, 2012.

lsi Juan P. Bauta, II

By: JUAN P. BAUTA, II, ESQ. Florida Bar No. 894060

2 Plaintiff also discussed extending the discovery cutoff with Dffendants. in large part because counsel for Plaintiff will be in a 3-week trial starting mid-July. Defendants stated they objected to that as well. Plaintiff. however. does anticipate filing such a motion in light of counse]"s trial S( hedule.

Case 9:11-cv-80880-KLR Document 91-1 Entered on FLSD Docket 06/12/2012 Page 1 of 1

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO: 11-80880-CIV-KLR

QSGI, Inc" a Delaware Corporation, Plaintiff, v. IBM GLOBAL FINANCING, et al. Defendants.

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ORDER GRANTING PLAINTIFF'S RENEWED MOnON FOR EXTENSION OF TIME TO FILE EXPERT WITNESS DISCLOSURES
THIS CAUSE having come before the Court on Plaintiff's Renewed Motion for Extension of Time to File Expert Witness Disclosures and the Court having considered Plaintiff's 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 Disclosure, on or before July 15, 2012. DONE AND ORDERED in Chambers at West Palm Beach, Florida, this _____________________, 2012. day of

KENNETH L. RYSKAMP UNITED STATES DISTRICT JUDGE