CORBACHO DAUDINOT v. PUIG VALDES et al

Filing 19

Unopposed MOTION to Continue Oral Argument that was set for November 25, 2013 by MIGUEL ANGEL CORBACHO DAUDINOT. Responses due by 11/25/2013 (Bravo, Kenia)

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIGUEL ANGEL CORBACHO DAUDINOT Plaintiff, CASE NO.: 1:13-cv-22589-KMW v. YASIEL PUIG VALDES a/k/a YASIEL PUIG and MARITZA VALDES GONZALEZ. Defendants. ______________________________________/ PLAINTIFF’S UNOPPOSED MOTION FOR CONTINUANCE OF ORAL ARGUMENT Plaintiff, by and through the undersigned counsel, and pursuant to FLSD Local Rule 7.6, respectfully moves for a continuance of the Oral Argument hearing of Defendants’ Motion to Dismiss [DE 11], and in support thereof states: 1. The court entered a sua sponte order on November 6, 2013 setting Defendants’ Motion to Dismiss [DE 11] for oral argument on November 25, 2013. 2. Plaintiff’s counsel has a court-ordered mediation in the case of Garcia et al v. Chapman Bennett et al, Case No. 13-cv-22210-CMA, that was set several months ago and conflicts with the Oral Argument scheduled in this matter. 3. Plaintiff’s counsel is also scheduled on November 26, 2013 to appear before the Honorable Judge Altonaga for Oral Arguments to determine several motions still outstanding in the case of Garcia v. Chapman, Case No. 12-cv-21891-CMA, which is currently set to begin trial on December 16, 2013 and has a calendar call of December 10, 2013. WHEREFORE, Based on the above-mentioned pre-set Federal court obligations, the Plaintiff respectfully requests that this honorable court enter an order granting a continuance and re-setting the Oral Argument for a date after November 26, 2013. Local Rule 7.1(a)(3) Certification Undersigned counsel has conferred in writing with counsel for Defendants, Sean R. Santini, regarding this motion and certifies that Mr. Santini has no objection to Plaintiff’s filing for Continuance of the Oral Argument. By: s/Kenia Bravo _ Kenia Bravo, Esq., FBN 68296 Avelino J. Gonzalez, Esq., FBN 75530 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the forgoing document was filed using CM/ECF and that there are not other persons of interest who need to be served. By: s/Kenia Bravo _ Kenia Bravo, Esq., FBN 68296 Avelino J. Gonzalez, Esq., FBN 75530 Law Offices of Avelino J. Gonzalez, P.A. 6780 Coral Way, Miami, Florida 33155 Ph: 305-668-3535; Fax: 305-668-3545 E-mail: AvelinoGonzalez@bellsouth.net 2

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