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Employment Attorneys

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

NELSON FERNANDEZ

Plaintiff,

v.

THE WALKING COMPANY, a foreign forprofit corporation

Defendant.

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Case No. 9:20-cv-80469

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO RESPOND TO THE COMPLAINT

Defendant, THE WALKING COMPANY, (“Defendant”) respectfully moves for a brief 

extension of time up to and including May 22, 2020, to answer, move, or otherwise respond to 

Plaintiff’s Complaint, and state the following in support: 

1. Plaintiff filed the Complaint on March 23, 2020 and served Defendant with the Summons 

and Complaint on April 1, 2020 (Doc 3). Accordingly, Defendant is due to respond to the 

Complaint on or before April 22, 2020.

2. When an act may or must be done within a specified time, the Court may, for good cause, 

extend the time, with or without motion or notice, if the request is made before the original time 

or its extension expires. See Fed. R. Civ. P. 6(b).

3. This request is being made before the original deadline expires.

4. Defendant’s counsel is in the process of intaking and reviewing Defendant’s files relevant 

to the underlying litigation. In order to fully investigate and formulate an appropriate response(s) 

to the Complaint on behalf of the Defendant, counsel for Defendant requests a brief extension of 

Case 9:20-cv-80469-KAM Document 5 Entered on FLSD Docket 04/21/2020 Page 1 of 3
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time, up to and including May 22, 2020, to respond to Plaintiff’s Complaint. Furthermore, counsel 

for the parties are engaging in early discussions to determine if amicable resolution is possible.

5. This extension is not being sought for the purposes of delay, nor will this brief extension 

prejudice any party to the litigation.

6. The undersigned has discussed the subject matter of this Motion with Plaintiff’s counsel, 

who is not opposed to the relief sought herein. 

WHEREFORE, Defendant respectfully request an extension of time up to and including 

May 22, 2020, to answer, move or otherwise respond to Plaintiff’s Complaint. 

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LOCAL RULE 7.1(a)(3) CERTIFICATE

Counsel for Defendant has conferred with counsel for Plaintiff who has no objection to 

the relief requested.

DATED this 21st day of April, 2020.

Respectfully submitted,

Spire Law, LLC

12249 Science Drive, Suite 155

Orlando, Florida 32826

By: /s/Heather M. Meglino

Heather M. Meglino, Esq.

Florida Bar No. 91857

heather@spirelawfirm.com

 brook@spirelawfirm.com

Attorney for Defendant | The Walking Company

CERTIFICATE OF SERVICE

I hereby Certify that on this 21st day of April, 2020, the foregoing was electronically filed 

with the Court by using the Southern District of Florida’s CM/ECF portal, which will send a notice 

of electronic filing to: Pelayo M. Duran, Esq. at duranandassociates@gmail.com at 4640 N.W. 7th 

Street, Miami, FL 33126-2309 and Roderick Victor Hannah, Esq. at rhannah@rhannahlaw.com at 

8751 W. Broward Blvd., Suite 303, Plantation, FL 33324.

/s/ Heather M. Meglino

Heather M. Meglino, Esq.

Case 9:20-cv-80469-KAM Document 5 Entered on FLSD Docket 04/21/2020 Page 3 of 3