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IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

DANIEL LUGO, 

Case No. 9:22-cv-81539-DMM

Plaintiff,

v.

KEY ENDEAVORS, LLC,

Defendant.

________________________________/

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFF’S COMPLAINT

Defendant, Key Endeavors, LLC (“Defendant”), by and through its 

undersigned counsel, respectfully moves for an extension of time, up to and 

including November 23, 2022, to respond to Plaintiff’s Complaint, and states the 

following in support: 

1. On October 5, 2022, Plaintiff filed the Complaint. (Doc. 1).

2. Defendant was served on October 13, 2022, and, as such, Defendant’s 

deadline to respond to Plaintiff’s Complaint is currently November 3, 2022. 

3. Defendant only recently retained the undersigned counsel in this matter. 

4. Defendant and the undersigned counsel are in the process of reviewing the 

issues raised in Plaintiff’s Complaint and gathering information relevant to 

the response and defense of this matter. 

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5. For the foregoing reasons, Defendant respectfully requests additional time 

to file its response to Plaintiff’s Complaint. 

6. Defendant has conferred with Plaintiff’s counsel regarding the extension of 

time to respond to the Complaint, as requested herein, and Plaintiff has no 

objection to the requested extension.

MEMORANDUM OF LAW

 The Court may grant an enlargement of time for good cause shown when 

the request is made before the original time expires. Fed. R. Civ. P. 6(b).

Defendant’s request for an extension is made in good faith and does not prejudice 

Plaintiff. In fact, Plaintiff agrees to the proposed extension. Permitting the 

extension will enable Defendant to develop a response to the allegations in the 

Complaint following analysis of the relevant files and possibly discuss early 

resolution of the case. For these reasons, Defendant requests that the Court extend 

the deadline to respond to the Complaint.

LOCAL RULE 7.1(a)(3) CERTIFICATION

Counsel for Defendant hereby certifies that she has conferred with Plaintiff’s 

counsel regarding this motion and that Plaintiff does not oppose the relief 

requested herein. 

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WHEREFORE, Defendant, Key Endeavors, LLC, respectfully requests an 

extension of time, up to and including November 23, 2022, to respond to Plaintiff’s 

Complaint.

Dated this 25th day of October, 2022. 

Respectfully submitted,

SPIRE LAW, PLLC

2572 W. State Road 426, Suite 2088

Oviedo, Florida 32765

By: /s/ Alyssa Castelli

Alyssa Castelli

Florida Bar No. 1032306 

Jesse I. Unruh, Esq.

Florida Bar No. 93121

alyssa@spirelawfirm.com 

jesse@spirelawfirm.com 

marcela@spirelawfirm.com

filings@spirelawfirm.com

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on this 25th day of October 2022, the foregoing was 

electronically filed through the CM/ECF system, which will send a notice of 

electronic filing to Plaintiff’s counsel, Drew M. Levitt, Esquire and Lee D. Sarkin, 

Esquire, 4700 N.W. Boca Raton Boulevard, Suite 302, Boca Raton, Florida 33431, at 

drewmlevit@gmail.com, and lsarkin@aol.com. 

/s/ Alyssa Castelli 

 Attorney

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