Corbacho Daudinot v. Puig Valdes et al

Filing 43

Defendant's MOTION for Extension of Time to File Answer RE: Complaints re 24 Amended Complaint,, Defendant's by YASIEL PUIG VALDES. (Attachments: # 1 Text of Proposed Order Unopposed Order Mot 4 Extension of Time)(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 ANSWER 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 August 1, 2014, in which to file their answer and affirmative
defenses to the second amended complaint [ECF No. 24]. The grounds for this motion
are:
1.

On June 25, 2014, the Court entered an order denying defendants’ motion

to dismiss the second amended complaint [ECF No. 40]. Pursuant to Fed. R. Civ. P.
12(a)(4)(A) and 6(d), defendants’ answer to the second amended complaint is due by
July 11, 2014.
2.

Undersigned counsel is in depositions this week in another matter pending

before the District Court for the Southern District of Florida and is scheduled to be out of

the country on vacation from July 16th to the 25th. For that reason, defendants request a
21-day extension of time in which to file and serve their answer and affirmative
defenses to the second amended complaint.
3.

The extension of time sought herein will not unduly delay these

proceedings, jeopardize any of the Court’s deadlines or prejudice any of the parties.
For the foregoing reasons defendants request an extension of time, up to and
including August 1, 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, Avelino J.
Gonzalez, regarding this motion and certifies that Mr. Gonzalez 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 July 8, 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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