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UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

RACHEL KITTL, 

Plaintiff, CASE NO. 9:20-cv-80785-RS 

vs. 

JOSEPH C. KEMPE PROFESSIONAL ASSOCIATION, 

a Florida profit corporation and, 

JOSEPH C. KEMPE, individually 

Defendants. 

______________________________________________/ 

UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO RESPOND TO COMPLAINT 

Pursuant to Federal Rule of Civil Procedure 6(b)(1), Defendants, Joseph C. Kempe 

Professional Association, and Joseph C. Kempe (“Defendants”), respectfully request an 

extension of time, up to and including Friday, July 10, 2020, to file a response to Plaintiff’s 

Complaint (“Complaint”) [D.E. 1], and in support thereof states: 

1. Plaintiff’s Complaint was filed on May 13, 2020. Defendants accepted service of 

the Complaint on May 20, 2020. As a result, Defendants’ current deadline to respond to the 

Complaint is June 10, 2020.

2. The parties have reached a resolution of this matter. Moreover, the parties filed a 

Joint Motion for Approval of their Settlement Agreement. See D.E. 6. 

3. On June 22, 2020, the Court entered an Order setting a Fairness Hearing 

(“Hearing”) for June 10, 2020. See D.E. 7. The Hearing is scheduled for the same date as 

Defendants’ deadline to respond to the Complaint. 

4. The Hearing will likely obviate the need for the filing of a responsive pleading 

and conserve the time and resources of both the parties and of the Court.

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5. Defendants, therefore, request a 30-day extension of time, through and including 

Friday, July 10, 2020, within which to file its response to the Complaint.

6. This motion is made in good-faith and not for the purpose of delay, and no party 

will be prejudiced by the relief sought. 

CERTIFICATE OF CONFERENCE 

7. Pursuant to S.D. Fla. L.R. 7.1.A.3, the undersigned certifies that prior to filing 

this motion, undersigned counsel conferred with Plaintiff’s counsel, Cathleen Scott, regarding 

the relief sought herein and is authorized to represent that Plaintiff does not oppose to the relief 

sought by this motion. 

8. A proposed Order is attached as Exhibit A. 

WHEREFORE, Joseph C. Kempe Professional Association, and Joseph C. Kempe, 

respectfully requests that the Court enter an Order granting it an extension of time, up to and 

including Friday, July 10, 2020, within which to file its response to the Complaint, together with 

any such other and further relief the Court deems appropriate. 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via 

transmission of Notice of Electronic Filing generated by CM/ECF this 26th day of May, 2020, 

which will send notice electronically to the counsel or parties of record on the Service List 

below. 

GRAYROBINSON, P.A. 

Counsel for Defendants, Joseph C. Kempe 

Professional Association and Joseph C. Kempe

333 S.E. 2nd Avenue, Suite 3200 

Miami, Florida 33131 

Telephone: (305) 416-6880 

Facsimile: (305) 416-6887 

By: /s/ Anastasia Protopapadakis

 Anastasia Protopapadakis, FBN 051426 

anastasia.protopapadakis@gray-robinson.com 

SERVICE LIST 

Cathleen Scott, Esq. 

cscott@scottwagnerlaw.com

SCOTT WAGNER & ASSOCIATES, P.A.

250 South Central Boulevard, Suite 104-A 

Jupiter, Florida 33458 

Telephone: (561) 653-0008 

Facsimile: (561) 653-0020 

Counsel for Plaintiff, Rachel Kittl 

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