UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 9:22-cv-81538-AMC 

NELSON FERNANDEZ, 

Plaintiff, 

v. 

STARBUCKS CORPORATION, a Foreign 

for-profit corporation, 

Defendant. 

DEFENDANT’S SECOND UNOPPOSED MOTION FOR AN EXTENSION OF TIME 

TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT 

Defendant, Starbucks Corporation (“Defendant”) by its attorneys and pursuant to Federal 

Rule of Civil Procedure 6(b)(1), respectfully moves for a 20-day extension of time, through and 

including December 16, 2022, to answer or otherwise respond to Plaintiff’s Complaint. 

Defendant submits the following facts in support of its motion: 

1. On October 6, 2022, Defendant was served with the Complaint. Defendant’s 

response was due on October 27, 2022. 

2. On October 20, 2022, the Court granted Defendant’s first request for an extension 

of Defendant’s responsive pleading deadline. Defendant’s deadline to respond to the Complaint 

is November 26, 2022. (ECF No. 6.) 

3. Defendant requested from Plaintiff an extension of time to December 16, 2022 to 

file a responsive pleading. Plaintiff has consented to this request. 

4. The extension of time will give the parties to discuss ways to resolve the case 

without further litigation. 

5. This motion is filed in good faith and it is the second such request for an 

Case 9:22-cv-81538-AMC Document 7 Entered on FLSD Docket 11/21/2022 Page 1 of 3
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extension of time. 

6. Defendant’s request is not sought for the purpose of delay, nor will the additional 

time adversely affect the prospect of a just, speedy, and inexpensive determination of this action. 

See Fed. R. Civ. P. 1. 

7. In accordance with Local Rule 7.1.(a)(2) and Section 31(6) of the CM/ECF 

Administrative Procedures, Defendant is filing a copy of a Proposed Order herewith and emailing a Word version of the same to the presiding judge. 

WHEREFORE, Defendant respectfully requests that this Court grant its Unopposed 

Motion for an Extension of Time to Answer or Otherwise Respond to Plaintiff’s Complaint, and 

allow Defendant until December 16, 2022 to file a responsive pleading. 

CERTIFICATION OF PRE-FILING CONFERENCE 

In accordance with Local Rule 3.01(g), Defendant’s counsel certifies that it conferred in 

good faith with Plaintiff’s counsel, and Plaintiff’s counsel consents to the relief requested herein. 

Date: November 21, 2022 Respectfully submitted, 

SEYFARTH SHAW LLP 

By s/ Kevin M. Young

Kevin M. Young 

Florida Bar No. 114151 

SEYFARTH SHAW LLP 

1075 Peachtree Street, N.E., Suite 2500

Atlanta, Georgia 30309-3958 

Telephone: (404) 885-1500 

E-mail: kyoung@seyfarth.com 

COUNSEL FOR DEFENDANT

Case 9:22-cv-81538-AMC Document 7 Entered on FLSD Docket 11/21/2022 Page 2 of 3
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 9:22-cv-81538-AMC 

NELSON FERNANDEZ, 

Plaintiff, 

v. 

STARBUCKS CORPORATION, a foreign 

for-profit corporation, 

Defendant. 

CERTIFICATE OF SERVICE 

I hereby certify that on November 21, 2022, I electronically filed DEFENDANT’S 

SECOND UNOPPOSED MOTION FOR AN EXTENSION OF TIME TO ANSWER OR 

OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT with the Clerk of Court using the 

CM/ECF system, which will send e-mail notification of such filing to all attorneys of record. 

s/ Kevin M. Young 

Counsel for Defendant 

Case 9:22-cv-81538-AMC Document 7 Entered on FLSD Docket 11/21/2022 Page 3 of 3