Corbacho Daudinot v. Puig Valdes et al

Filing 5

Unopposed MOTION for Extension of Time to File Answer RE: Complaints re 1 Complaint,, by YASIEL PUIG VALDES, MARITZA VALDES GONZALEZ. Attorney Sean R. Santini added to party YASIEL PUIG VALDES(pty:dft), Attorney Sean R. Santini added to party MARITZA VALDES GONZALEZ(pty:dft). (Attachments: # 1 Text of Proposed Order)(Santini, Sean)

CORBACHO DAUDINOT v. PUIG VALDES et al

Doc. 5

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 RESPOND TO 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 10-day extension of time in
which to submit their response to the complaint. The grounds for this motion are:
1.

Defendants’ response to complaint is currently due on August 12, 2013.

2.

Undersigned counsel has been out of the country and, due to the press of

other work upon his return, is unable to prepare defendants’ response to the complaint
by August 12. For that reason, defendants request a 10-day extension of time in which
to submit their response.
3.

The extension of time sought herein will not unduly delay these

proceedings or prejudice any of the parties.

Dockets.Justia.com

EMI SUN VILLAGE, INC, et al.. v. JAMES B. CATLEDGE, et al..
Case No. 1:13-cv-21594-KMM

For the foregoing reasons defendants request a 10-day extension of time, up to
and including August 22, 2013, in which to submit their response to the 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 10-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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EMI SUN VILLAGE, INC, et al.. v. JAMES B. CATLEDGE, et al..
Case No. 1:13-cv-21594-KMM

CERTIFICATE OF SERVICE
I hereby certify that on August 8, 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.

__________________________
Sean R. Santini

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EMI SUN VILLAGE, INC, et al.. v. JAMES B. CATLEDGE, et al..
Case No. 1:13-cv-21594-KMM

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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