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 A RENEWED JOINT 

SCHEDULING REPORT

Pursuant to Rule 6(b)(1)(A) of the Federal Rules of Civil Procedure, Plaintiff, JORGE

MONTEAGUDO ALBURQUERQUE (“Plaintiff”), through his undersigned counsel, hereby 

moves for an enlargement of time to file a Renewed Joint Scheduling Report in accordance with 

this Court’s Paperless Order Requiring a Renewed Joint Scheduling 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 Renewed Joint Scheduling Report 

“setting forth proposed further proceedings forth the Court to take in this case” on or before 

October 10, 2024. (ECF. No. 139).

Case 1:22-cv-22343-KMM Document 142 Entered on FLSD Docket 10/17/2024 Page 1 of 5
2. Counsel for Plaintiff has prepared a proposed draft of the Joint Scheduling Report, however 

due to scheduling conflicts on the dates proposed, the Parties need additional time to confer on 

a mutually agreeable date for trial to submit their status report jointly as required by the Order.

3. During a conferral call, on October 17, 2024, Defendant’s counsel Reginald Clyne advised the 

undersigned of his limited availability in November and December 2024 and proposed dates 

in January 2025. Defendant’s counsel further advised that at this time his ability to confer with 

his client is limited as Defendant is performing Hurricane Milton emergency repairs out in the 

field. Accordingly, Counsel for the parties agreed to seek a brief extension to allow the parties 

a few additional days to coordinate their availability. 

4. 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). 

5. 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 Renewed Joint Scheduling Report. See 

(ECF No. 139); Fed. R. Civ. P. 6(b)(1)(A). 

6. Accordingly, Plaintiff respectfully requests an extension of the deadline for the Parties to 

submit the Renewed Joint Scheduling Report until October 24, 2024. 

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

proceedings or prejudice the opposing party.

Case 1:22-cv-22343-KMM Document 142 Entered on FLSD Docket 10/17/2024 Page 2 of 5
8. This Motion is filed in good faith and not for the purpose of harassment or delay. 

WHEREFORE, Plaintiff, JORGE MONTEAGUDO ALBURQUERQUE respectfully requests 

that this Court grant his Motion for Enlargement of Time to file the Renewed Joint Scheduling 

Report.

Dated: October 17, 2024 Respectfully submitted,

/s/ Nathaly Saavedra 

Nathaly Saavedra, Esq. 

Fla. Bar No. 118315

Email: nathaly@peregonza.com

Juan J. Perez, Esq. 

Fla. Bar No. 115784

Email: juan@peregonza.com

P. Brooks, LaRou, Esq. 

Fla. Bar No. 1039018

Email: brooks@peregonza.com

PEREGONZA THE ATTORNEYS, PLLC

5201 Blue Lagoon Drive,

Suite 290, 

Miami, FL 33126

Tel. (786) 650-0202

Fax. (786) 650-0200

Counsel for Plaintiff

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on October 17 , 2024, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record or pro se parties identified on the attached Service 

List in the manner specified, either via transmission of Notices of Electronic Filing generated by 

CM/ECF or in some other authorized manner for those counsel or parties who are not authorized 

to receive electronically Notices of Electronic Filing.

/s/ Nathaly Saavedra

Nathaly Saavedra, Esq. 

Case 1:22-cv-22343-KMM Document 142 Entered on FLSD Docket 10/17/2024 Page 4 of 5
SERVICE LIST

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

Case No. 1:22-cv-22343-KMM Moore/Louis

Nathaly Saavedra, Esq. 

Fla. Bar No. 118315

Email: nathaly@peregonza.com

Juan J. Perez, Esq. 

Fla. Bar No. 115784

Email: juan@peregonza.com

PEREGONZA THE ATTORNEYS, PLLC

5201 Blue Lagoon Drive,

Suite 290, 

Miami, FL 33126

Tel. (786) 650-0202

Fax. (786) 650-0200

Attorneys for Plaintiff

Method of Service: CM/ECF notice

Reginald J. Clyne, Esq.

Florida Bar No. 654302

reginald.clyne@qpwblaw.com

Chanelle Artiles, Esq. 

Florida Bar No. 10006402

chanelle.artiles@qpwblaw.com

Quintairos, Prieto, Wood & Boyer, P.A.

9300 South Dadeland Blvd., 4th Floor

Miami, Florida 33156

Telephone: 305-670-1101

Attorneys for Defendant

Method of Service: CM/ECF notice

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