IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA
Land Rover, a foreign company,
, v.Rover Repair’s of Collingdale, LLC,
.Case No. 2:12-cv-05036-ABHon. Anita B. Brody
Motion for an Extension of Timeto Reply to Plaintiff's Complaint
Motion for An Extension of Time to Reply to Plaintiff'sComplaint
1.The Defendant was previously employed by the LandRover dealership in Wayne, Pennsylvania.
In June, 2008, the Defendant began doing business asRover Repair’s of Collingdale, LLC.
The Defendant operated openly,advertising the name of his business, and putting up a website inNovember 2008 at <roverrepairs.com>.3.Despite the Defendant’s operation for more than fouryears under this name, Land Rover, International (for unknown reas-ons that will be explored if discovery commences) decided to bring itslegal hammer down upon this small independent Rover repair busi-ness.
Unable to afford counsel, Rover Repair’s of Collingdale’sowner, Frank Dalahan, sought to represent his business
Dalahan was unaware of the rule that a business entitymay not be represented
, and led a Motion to Dismiss. (Dkt. 9)6.The Plaintiff opposed this Motion. (Dkt. 10).
The Defendant uses the possessive in its company name.
Case 2:12-cv-05036-AB Document 17 Filed 12/23/12 Page 2 of 15