Saccato v. Davis Law Firm et al

Motion for Extension of Time to File First Appearance.

D. Or.October 27, 2010

Page 1 - DEFENDANT DAVIS LAW FIRM’S MOTION FOR EXTENSION OF TIME TO FILE FIRST APPEARANCE 1073378.doc COSGRAVE VERGEER KESTER LLP Attorneys 805 SW Broadway, 8 th Floor Portland, OR 97205 (503) 323-9000 Robert E. Sabido, OSB No. 96416 rsabido@cvk-law.com COSGRAVE VERGEER KESTER LLP 805 SW Broadway, 8th Floor Portland, Oregon 97205 Telephone: (503) 323-9000 Facsimile: (503) 323-9019 Attorneys for Defendant Davis Law Firm IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON EUGENE DIVISION LAWRENCE JAMES SACCATO, Plaintiff, v. DAVIS LAW FIRM, U.S. BANK NATIONAL ASSOCIATION N.D., DOES 1 through 10, Defendants. Case No. CV10-6244 AA DEFENDANT DAVIS LAW FIRM’S MOTION FOR EXTENSION OF TIME TO FILE FIRST APPEARANCE Pursuant to FRCP 6(b), defendant Davis Law Firm moves to extend the deadline to file its first appearance to November 24, 2010. This motion is supported by the accompanying declaration of Robert E. Sabido. Defendant Davis Law Firm’s counsel certifies that he made a good faith effort to contact the pro se plaintiff by telephone to confer on this motion, including leaving a message for plaintiff to call back, but was unable to reach plaintiff. / / / / / / / / / / / / Case 6:10-cv-06244-AA Document 3 Filed 10/27/10 Page 1 of 3 Page ID#: 19 Page 2 - DEFENDANT DAVIS LAW FIRM’S MOTION FOR EXTENSION OF TIME TO FILE FIRST APPEARANCE 1073378.doc COSGRAVE VERGEER KESTER LLP Attorneys 805 SW Broadway, 8 th Floor Portland, OR 97205 (503) 323-9000 This motion does not waive any defenses or claims that Davis Law Firm may have, including (but not limited to) any defenses based on jurisdiction, venue, process, service of process, or statute of limitations. DATED: October 27, 2010 COSGRAVE VERGEER KESTER LLP /s/ Robert E. Sabido Robert E. Sabido, OSB No. 96416 rsabido@cvk-law.com Telephone: (503) 323-9000 Fax: (503) 323-9019 Attorneys for Defendant Davis Law Firm Case 6:10-cv-06244-AA Document 3 Filed 10/27/10 Page 2 of 3 Page ID#: 20 Page 1 - CERTIFICATE OF SERVICE 1073378.doc COSGRAVE VERGEER KESTER LLP Attorneys 805 SW Broadway, 8 th Floor Portland, OR 97205 (503) 323-9000 CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing DEFENDANT DAVIS LAW FIRM’S MOTION FOR EXTENSION OF TIME TO FILE FIRST APPEARANCE on the date indicated below by: mail with postage prepaid, deposited in the US mail at Portland, Oregon, hand delivery, facsimile transmission, overnight delivery, electronic filing notification; I further certify that said copy was placed in a sealed envelope delivered as indicated above and addressed to said attorney(s) at the address(es) listed below: Lawrence James Saccato c/o 6387 Old 99 S. Roseburg, OR 97471 Plaintiff pro se DATED: October 27, 2010 /s/ Robert E. Sabido Robert E. Sabido Case 6:10-cv-06244-AA Document 3 Filed 10/27/10 Page 3 of 3 Page ID#: 21