LAW OFFICES OF ANTHONY F. SANCHEZ, P.A. 

6701 SUNSET DRIVE, SUITE 101, MIAMI, FL, 33143 • TELEPHONE (305) 665-9211

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Miami Division

Case No.: 1:20-cv-22603-GOODMAN

[CONSENT]

Erik Chavez, individually, and on behalf of 

others similarly situated,

Plaintiff,

vs.

Grill Enterprises, LLC, a Florida limited 

liability company, d/b/a “Los Parrilleros” and 

“Parrilleros Tavern”, and; 

Ruben Sierra, individually, 

Defendants.

PLAINTIFFS’ MOTION TO RESCHEDULE ZOOM HEARING 

Plaintiffs, by and through undersigned counsel, submit the instant Motion to Reschedule 

the Zoom Hearing, and in support thereof, state as follows: 

1. The above-captioned case was, until recently, scheduled for a specially set jury trial 

to take place May 8, 2023 through May 11, 2023. See ECF No. 130. 

2. Plaintiff Erik Chavez traveled to the jurisdiction from his current home in 

Oklahoma for the very purpose of attended the special set jury trial. 

3. On Sunday, May 7, 2023, the Court entered its “Paperless Order” cancelling the 

May 8, 2023 trial and subsequent “Order Re: Trial Postponement”. ECF Nos. 183 and 184, 

respectively. 

4. This afternoon (May 8th), the Court entered its “Order Re: Trial Rescheduling, 

Briefing and Questions” [ECF No. 185] which, inter alia, set a Zoom hearing for Friday, May 12, 

2023 at 9:30 a.m. to discuss trial rescheduling and other matters. 

Case 1:20-cv-22603-JG Document 186 Entered on FLSD Docket 05/08/2023 Page 1 of 3
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5. Undersigned counsel for the Plaintiffs has prepaid arrangements to be away from 

the district from Friday, May 12, 2023 through Sunday, May 13, 2023 to attend his 35-year law 

school reunion at the University of Pennsylvania. See attached Exhibit 1. 

6. Accordingly, undersigned counsel respectfully requests the Court reschedule the 

Zoom hearing currently scheduled for Friday, May 12, 2023 at 9:30 a.m. 

7. Undersigned counsel is available anytime the remainder of this week (except 

Friday, May 12th) and anytime next week.

8. Undersigned counsel has conferred with opposing counsel for the Defendants, who 

has advised that Defendants are available anytime this Thursday, May 11th, for a rescheduled 

hearing. 

WHEREFORE, Plaintiffs pray this Honorable Court grant their Motion to Reschedule 

Zoom Hearing to any of the alternative dates the parties are mutually available, as set forth in ¶ 8, 

above, and award such further relief the Court may deem meet and proper under the circumstances 

of this case.

CERTIFICATE OF CONFERRAL

In accordance with S.D.Fla. L.R. 7.1(a)(3), undersigned counsel certifies he has conferred 

with opposing counsel for the Defendants, who does not oppose the relief sought herein. 

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CERTIFICATE OF SERVICE

I hereby certify that on May 8, 2023 a true and correct copy of the foregoing was 

electronically filed with the Clerk of the Court via CM/ECF and served on the parties listed in the 

Service List below in the manner indicated therein.

Anthony F. Sanchez, P.A. Attorneys for Plaintiffs

6701 Sunset Drive, Suite 101

Miami, Florida 33143

Tel.: 305-665-9211

By: /s/ Anthony F. Sanchez

Anthony F. Sanchez

Florida Bar No.789925

afs@laborlawfla.com

SERVICE LIST

Anthony F. Sanchez, Esq.

Florida Bar No.: 789925 

afs@laborlawfla.com 

faz@laborlawfla.com 

Counsel for Plaintiffs

ANTHONY F. SANCHEZ, P.A.

6701 Sunset Drive, Suite 101 

Miami, Florida 33143 

Tel: 305-665-9211 

Todd W. Shulby, Esq.

Florida Bar No.: 068365 

tshulby@shulbylaw.com

llangford@shulbylaw.com 

Counsel for Defendants 

TODD W. SHULBY, P.A.

1792 Bell Tower Lane

Weston, Florida 33326 

Tel: 954-530-2236 

Fax: 954-530-6628 

Via Notice of Electronic Filing

Brian H. Pollock, Esq. 

Florida Bar No.: 174742 

brian@fairlawattorney.com

Co-Counsel for Defendants 

FAIRLAW FIRM

135 San Lorenzo Avenue, Suite 770 

Coral Gables, Florida 33146 

Tel: 305-230-4884 

Via Notice of Electronic Filing

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