UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

JONATHAN VARGAS, individually and 

on behalf of others similarly situated,

Plaintiff, Case No. 1:20-cv-00224-AW-GRJ

v.

SQUEAKY KLEAN SERVICES, INC, 

a Foreign Profit Corporation,

Defendants.

________________________________________/

JOINT MOTION TO EXTEND THE DEADLINE 

TO FILE THE PARTIES MOTION FOR APPROVAL OF SETTLEMENT

Plaintiff, JONOTHAN VARGAS, individually and on behalf of the others similarly 

situated (“Plaintiff”) and Defendant, SQUEAKY KLEAN SERVICES, INC, A Foreign Profit 

Corporation, (Collectively “Parties”) respectfully move to extend the deadline for the parties to 

file their Motion for Approval of Settlement. In support thereof, Plaintiff states:

1. The parties reached a negotiated resolution of Plaintiffs’ claims against Defendant 

and the parties filed a Joint Notice of Settlement on March 10, 2021 [D.E. 17] wherein the 

parties advised the court they have reached a settlement, and are currently negotiating the nonmonetary terms, and are in the process of preparing and finalizing the necessary documents for 

final disposition of this matter.

2. On March 12, 2021, this Court entered on Order Recognizing Settlement [D.E. 

19], thus requiring the parties to move for approval of the settlement by, April 9, 2021. 

3. The parties have continued to diligently work towards finalizing the terms of the

Settlement Agreement, and Motion to Approve Settlement.
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4. Due to the nature of the settlement agreement, it has taken longer than anticipated 

to finalize the remaining details of the Settlement Agreement, and Motion to Approve 

Settlement. 

5. Thus, by this instant Motion, the parties respectfully request an extension of thirty

(30) days, or until May 10, 2021, to complete and file the parties Motion for Approval of 

Settlement.

6. The requested extension of time is not made for the purpose of delay, and no party 

will be prejudiced if the Court were to grant the requested extension. 

7. Counsel for the parties represent that this motion is made in good faith and not for 

the purpose of delay.

MEMORANDUM OF LAW

Under Federal Rule of Civil Procedure 6(b)(1), “[w]hen an act may or must be done 

within a specified time, the court may, for good cause, extend the time . . . if a request is made, 

before the original time or its extension expires . . . .” The parties seek this enlargement of time 

prior to the expiration of the deadline to file the parties Motion for Approval of Settlement, and 

have shown good cause for the requested enlargement. Moreover, this enlargement is sought in 

good faith and not for purposes of delay.

WHEREFORE, the parties move for the entry of an Order extending the deadline to file 

the parties Motion for Approval of Settlement documents by thirty (30) days or up to and 

including May 10, 2021.
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Dated: April 8, 2021

/s/ Andrew R. Frisch

Andrew R. Frisch 

Morgan & Morgan, P.A.

8151 Peters Road, Suite 4000

Plantation, FL 33324

T: (954) WORKERS 

F: (954) 327-3013

Counsel Plaintiffs

/s/ Jesse I. Unruh

Jesse I. Unruh, Esq.

SPIRE LAW, LLC

2572 W. State Road 426, Suite 2088

Oviedo, Florida 32765

T: (407)494-0135

Counsel for Defendants

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of April 2021, I electronically filed the foregoing with 

the Clerk of the Court by using the CM/ECF system which I understand will send a notice of 

electronic filing to all parties of record.

/s/ ANDREW R. FRISCH

Andrew R. Frisch