Corbacho Daudinot v. Puig Valdes et al

Filing 13

Defendant's MOTION for Extension of Time to File Response/Reply as to 11 MOTION to Dismiss 10 Amended Complaint, by YASIEL PUIG VALDES, MARITZA VALDES GONZALEZ. (Attachments: # 1 Text of Proposed Order Proposed Order on Unopposed Motion for Enlargement of Time)(Santini, Sean)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION
CASE NO.: 1:13-cv-22589-KMW
MIGUEL ANGEL CORBACHO
DAUDINOT
Plaintiff,
v.
YASIEL PUIG VALDES a/k/a
YASIEL PUIG and MARITZA
VALDES GONZALEZ,
Defendants.
_________________________/
DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE REPLY IN SUPPORT OF MOTION TO DISMISS
Defendants, Yasiel Puig Valdes a/k/a Yasiel Puig and Maritza Valdes Gonzalez,
pursuant to Fed. R. Civ. P. 6(b)(1)(A), hereby move for a 7-day extension of time – up to
and including October 31, 2013 -- in which to file their reply memorandum in support of
their motion to dismiss the first amended complaint [DE 11].

The grounds for this

motion are:
1.

On October 14, 2013, plaintiff filed his memorandum in opposition to

defendants’ motion to dismiss. [DE 12.] Pursuant to S.D. Fla. L.R. 7.1, defendants’
reply memorandum in support of their motion to dismiss is currently due on October 24,
2013.
2.

Due to the press of other work, including preparing for an evidentiary

hearing earlier this week in Miami-Dade County Circuit Court and preparing for a

hearing this Friday in U.S. Bankruptcy Court, undersigned counsel is unable to prepare
defendants’ reply memorandum by tomorrow, October 24. For that reason, defendants
request a 7-day extension of time – up to and including October 31, 2013 -- in which to
file their reply memorandum.
3.

The extension of time sought herein will not unduly delay these

proceedings or prejudice any of the parties.
For the foregoing reasons defendants request a 7-day extension of time, up to
and including October 31, 2013, in which to file their reply memorandum in support of
their motion to dismiss plaintiff’s first amended complaint.
Local Rule 7.1(a)(3) Certification
Undersigned counsel has conferred in writing with lead counsel for plaintiff, Kenia
Bravo, regarding this motion and certifies that Ms. Bravo has no objection to the 7-day
extension of time sought herein.
Respectfully submitted,
SANTINI LAW
1200 Brickell Avenue, Suite 950
Miami, Florida 33131
Tel: [phone]
Fax: [phone]
[e-mail]

By: /s/ Sean R. Santini
Sean R. Santini
Florida Bar No. 832898

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CERTIFICATE OF SERVICE
I hereby certify that on October 23, 2013, I electronically filed the foregoing
document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
document is being served this day on all counsel of record or pro se parties identified on
the attached Service List in the manner specified, either via transmission of Notices of
Electronic Filing generated by CM/ECF or in some other authorized manner for those
counsel or parties who are not authorized to receive electronically Notices of Electronic
Filing.

By: /s/ Sean R. Santini
Sean R. Santini

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SERVICE LIST

Kenia Bravo, Esq.
[e-mail]
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155
Avelino Jose Gonzalez, Esq.
[e-mail]
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155

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