Corbacho Daudinot v. Puig Valdes et al

Filing 8

Unopposed MOTION for Extension of Time to File Response/Reply to Defendants' Motion to Dismiss by MIGUEL ANGEL CORBACHO DAUDINOT. (Gonzalez, Avelino)

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.
______________________________________/

PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS [DE 7]
Plaintiffs, by and through the undersigned counsel, and pursuant to Fed. R. Civ. P.
6(b)(1)(A), respectfully move for a 7-day extension of time to respond to Defendants’ Motion to
Dismiss [DE 7], and in support thereof state :
1.

Defendants filed a Motion to Dismiss [DE 7] on August 22, 2013. Plaintiffs’

response to Defendants’ motion is due on September 5, 2013.
2.

When Defendants’ motion was filed, the undersigned counsel was away from the

office on a previously scheduled vacation. Upon her return, the undersigned received Plaintiffs’
motion, among other legal work that accumulated during the short period counsel was away. Due
to the enormity of her workload, and the many issues raised in Defendants’ motion, the
undersigned counsel is unable to prepare Plaintiffs’ response by September 5, 2013, and
respectfully requests a 7-day extension of time in which to submit a response.
3.

In anticipation that Plaintiffs would be unable to meet the September 5 deadline,

the undersigned counsel contacted Defendants’ counsel, Sean R. Santini, and, after explaining
the undersigned’s need for additional time, asked Mr. Santini if Defendants’ would be willing to
agree to provide Plaintiffs with a 7-day enlargement of time to file a response to Defendants’
motion. Mr. Santini graciously agreed.

4.

The 7-day extension of time sought in the instant motion will not unduly delay

these proceedings or prejudice any of the parties.
WHEREFORE, the Plaintiffs respectfully request that this honorable court enter an order
granting them a 7-day extension of time, up to and including September 12, 2013, in which to
submit their response to Defendants’ Motion to Dismiss [DE 7].
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 the 7-day
extension of time sought herein.
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: [phone]
E-mail: [e-mail]

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