Corbacho Daudinot v. Puig Valdes et al

Filing 26

MOTION for Extension of Time to File Response/Reply as to 24 Amended Complaint,, by YASIEL PUIG VALDES, MARITZA VALDES GONZALEZ. (Santini, Sean)

UNITED STATES DISTRICT COURT
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
DEFENDANTS’ RESPONSE TO THE SECOND AMENDED COMPLAINT
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 an extension of time – up to and
including February 10, 2014 -- in which to file their response to the second amended
complaint [DE 24]. The grounds for this motion are:
1.

Pursuant to the Court’s order of December 20, 2013 (DE 23), plaintiffs

filed their second amended complaint in this matter on January 13, 2014. Pursuant to
Fed. R. Civ. P. 15(a)(3), defendants’ response is due on January 23, 2014.
2.

Due to the press of other matters, including the preparation of a brief to

the Eleventh Circuit and hearings on a motion to dismiss and several discovery disputes
in a separate state court matter, undersigned counsel is unable to submit defendants’

response to the second amended complaint by the current deadline and, therefore,
requests an 18-day extension of time in which to do so.
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 an extension of time, up to and
including February 10, 2014, in which to file their response to the second amended
complaint.
Local Rule 7.1(a)(3) Certification
Undersigned counsel has conferred in writing with counsel for plaintiff, Kenia
Bravo, regarding this motion and certifies that Ms. Bravo has no objection to the
extension of time sought herein.
Respectfully submitted,
SANTINI LAW
1001 Brickell Bay Drive, Suite 2650
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 January 22, 2014, 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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