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To: flptrnkng who wrote (18201)2/1/2012 5:09:01 PM
From: scionRespond to of 53574
 
Bordynuik is domiciled in Canada, and has more time to respond. The change in date is for JBI and Baldwin only, and is intended to make the response date deadline the same for all three defendants.


DEFENDANTS’ ASSENTED-TO MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

Defendants JBI, Inc. (“JBI”), John W. Bordynuik, and Ronald Baldwin, Jr., with the assent of Plaintiff Securities and Exchange Commission (“SEC”), respectfully request that the Court extend the deadline for JBI and Baldwin to answer, move, or otherwise respond to the Complaint until April 5, 2012. In support of this Motion, Defendants state as follows:

1. On January 4, 2012, the SEC filed the Complaint in this action.

2. On January 5, 2012, the SEC sent Defendants requests for waivers of service pursuant to Fed. R. Civ. P. 4(d). All Defendants agreed to waive service of process.

3. Pursuant to Fed. R. Civ. P. 12(a)(1)(A)(ii), JBI’s and Baldwin’s responsive pleading is due on March 5, 2012, “60 days after the request for waiver is sent.” Because Bordynuik resides in Canada, the deadline for him to file a responsive pleading is April 5, 2012.
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