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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 22-cv-22343

JORGE MONTEAGUDO ALBURQUERQUE

Plaintiff,

v.

THE DE MOYA GROUP, INC.,

a Florida Profit Corporation,

Defendant.

____________________________________/

MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT

Pursuant to Rule 6(b)(1)(A) of the Federal Rules of Civil Procedure, Defendant, The De Moya 

Group, Inc. (“De Moya”), through its undersigned counsel, hereby moves for an enlargement of 

time to file the Joint Status Report in accordance with this Court’s Paperless Order Requiring 

Status Report issued on September 26, 2024 (the “Order”). (ECF. No. 139).

1. On September 13, 2024, the Mandate from the Eleventh Circuit remanding this case 

for further proceedings in accordance with the Eleventh Circuit’s opinion was filed. This Court 

then issued its September 26, 2024 Order requiring the Parties to file a Joint Status Report “setting 

forth proposed further proceedings forth the Court to take in this case” on or before October 10, 

2024. (ECF. No. 139).

2. Counsel for De Moya has prepared a draft status report, however, the Parties still 

need to confer in order to submit their status report jointly as required by the Order. The 

undersigned has made efforts by phone and email to confer with Plaintiff’s counsel on this matter 

but have not had the opportunity to do so.

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3. The Parties’ law offices are in Miami-Dade County, which is presently under a

tropical storm warning and weather advisories due to Hurricane Milton. Moreover, in anticipation 

of Hurricane Milton, federal and state courts in Miami-Dade are closed October 9 and 10.

4. One of Plaintiff’s attorneys, Nathaly Saavedra, responded to the undersigned’s 

conferral email this afternoon (October 9th) advising that their office would be closing early today

and closed tomorrow due to the storm. Ms. Saavedra also indicated in her email that they would 

make themselves available to confer, and De Moya’s counsel promptly responded that she was 

available. Nevertheless, in light of the current circumstances, the undersigned is submitting this 

extension request in an abundance of caution.

5. Under Rule 6(b)(1)(A), this Court may, for good cause, extend a deadline “if a 

request is made before the original time or its extension requires.” Fed. R. Civ. P. 6(b)(1)(A).

6. The deadline for the Joint Status Report has not yet expired, and the current 

conditions described herein present good cause to allow the Parties additional time to confer

regarding proposed further proceedings in this case and file the Joint Status Report. See (ECF No. 

139); Fed. R. Civ. P. 6(b)(1)(A). Accordingly, De Moya respectfully requests an extension of the 

deadline for the Parties to submit the Joint Status Report until October 15, 2024.

7. This brief extension to file the Joint Status Report will not delay the judicial 

proceedings or prejudice the opposing party.

8. This Motion is filed in good faith and not for the purpose of harassment or delay. 

WHEREFORE, Defendant, The De Moya Group, Inc., respectfully requests that this Court 

grant its Motion for Enlargement of Time to file the Joint Status Report.

Dated: October 9, 2024 Respectfully submitted,

By: /s/ Chanelle Artiles

Reginald J. Clyne, Esq.

Case 1:22-cv-22343-KMM Document 140 Entered on FLSD Docket 10/09/2024 Page 2 of 3
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Florida Bar No.: 654301

Chanelle Artiles, Esq.

Florida Bar No.: 1006402

Andres F. Vidales, Esq. 

Florida Bar No.: 1041185

Counsel for Defendant, The De Moya Inc.

9300 S. Dadeland Blvd., 4th Floor

Miami, FL 33156

Tel: (305) 670-1101

Fax: (305) 670-1161

Email: rclyne.pleadings@qpwblaw.com

reginald.clyne@qpwblaw.com

chanelle.artiles@qpwblaw.com

andres.vidales@qpwblaw.com

cecilia.quevedo@qpwblaw.com

sofia.arcila@qpwblaw.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on October 9, 2024, a true and correct copy of the foregoing was 

filed with the Clerk of Court via CM/ECF, which will send notice of electronic filing to attorneys 

for the Plaintiff, Nathaly Saavedra, nathaly@peregonza.com, Juan J. Perez, juan@peregonza.com, 

Peregonza The Attorneys, PLLC, and all other parties registered to receive service in this case. 

/s/ Chanelle Artiles

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