Corbacho Daudinot v. Puig Valdes et al
Filing
45
Unopposed MOTION for Extension of Time to File Answer RE: Complaints re 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’ SECOND 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 a one-week extension of time, up
to and including August 8, 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’ deadline to file the answer to the second amended
complaint was July 11, 2014.
2.
On July 8, 2014, defendants filed a motion for extension of time to answer
the second amended complaint. [ECF No. 43.] On July 8, 2014, the Court granted the
motion and extended defendants’ deadline to answer to August 1, 2014. [ECF No. 44.]
3.
Defendant Yasiel Puig is a Major League Baseball player for the Los
Angeles Dodgers whose schedule requires frequent travel. Due to Mr. Puig’s schedule,
undersigned counsel has been unable to confer with Mr. Puig to finalize defendants’
answer and affirmative defenses to the second amended complaint.
Undersigned
counsel anticipates that the one-week extension of time sought herein will be sufficient
time to confer with defendants and finalize their answer.
4.
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 8, 2014, in which to file their answer 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: (305) 372-7307
Fax: (305) 372-7308
ssantini@santinilawfirm.com
By: /s/ Sean R. Santini
Sean R. Santini
Florida Bar No. 832898
2
CERTIFICATE OF SERVICE
I hereby certify that on July 31, 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
3
SERVICE LIST
Kenia Bravo, Esq.
avelinogonzalez2@bellsouth.net
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155
Avelino Jose Gonzalez, Esq.
avelinogonzalez@bellsouth.net
Law Offices of Avelino J. Gonzalez, P.A.
6780 Coral Way
Miami, FL 33155
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