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Non-Tech : SLJB - Sulja Brothers Building Supply, Inc. -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (1469)	5/3/2007 1:31:02 PM
From: scion	Respond to of 1681

1. None of the defendants in this action has counsel. Although attorney Richard W. Markle filed a motion for extension of the defendants’ time to answer [D.E. 10], Mr. Markle has since filing that motion written to us by certified mail, and informed us that he is no longer representing any of the parties in this case. In that letter, Mr. Markle states that “the . . .parties refused to communicate with me relative to the issues in the above-mentioned matter.” Case 0:07-cv-60072-MGC Document 21 Entered on FLSD Docket 05/02/2007 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 07-60072-CIV-COOKE/BROWN _________________________________________ ) GLENN DRAGO, individually and on behalf ) of all others similarly situated, ) Plaintiff, ) v. )) SULJA BROTHERS BUILDING SUPPLIES Ltd., ) PETAR VUCICEVICH, STEVE SULJA ) and ANDREW DeVRIES, ) Defendants. )) __________________________________________) CERTIFICATE WITH RESPECT TO LOCAL RULE 7.1.A.3 With respect to Glenn Drago and Edward Bell’s Motion for Appointment as Lead Plaintiff [D.E.19], the undersigned states as follows under Local Rule 7.1.A.3: 1. None of the defendants in this action has counsel. Although attorney Richard W. Markle filed a motion for extension of the defendants’ time to answer [D.E. 10], Mr. Markle has since filing that motion written to us by certified mail, and informed us that he is no longer representing any of the parties in this case. In that letter, Mr. Markle states that “the . . .parties refused to communicate with me relative to the issues in the above-mentioned matter.” 2. Three of the defendants – Sulja Brothers Building Supplies Ltd., Petar Vucicevich, and Steve Sulja – have been served in the case. See Certificates of Service at D.E. 6, 9, 17. The Court set May 1, 2007 as the date by which they were to respond to the Complaint. [D.E. 12]. That date has passed, and neither of these three defendants has answered or otherwise responded. Counsel is still trying to locate the as yet unserved defendant, Andrew DeVries. 3. Undersigned counsel has no opposing attorney with whom to confer regarding the defendants’ position on this motion, and no means to telephone the unrepresented parties. However, counsel can represent that she served the unrepresented defendants with the earlier-filed versions of this motion, and no defendant filed any opposition to the relief sought herein. On this basis, counsel believes the motion to be unopposed. Dated: May 2, 2007 Respectfully Submitted, VIANALE & VIANALE LLP By: s/ Julie Prag Vianale Julie Prag Vianale Florida Bar No. 0184977 Kenneth J. Vianale Florida Bar No. 0169668 2499 Glades Road, Suite 112 Boca Raton, FL 33431 Telephone: (561) 392-4750 Facsimile: (561) 392-4775 JVianale@Vianalelaw.com DAVID R. CHASE, P.A. 1700 East Las Olas Boulevard Penthouse 2 Fort Lauderdale, FL 33301 Phone: (954) 920-7779 Fax: (954) 923-5622 Attorneys for Plaintiff - - - - -