UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 1:22-cv-23753-KMM

EDWIN GARRISON, et al., on behalf of 

themselves and all others similarly situated, 

Plaintiffs, 

v. 

SAM BANKMAN-FRIED, et al., 

Defendants. 

DEFENDANT SHOHEI OHTANI’S UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO RESPOND TO AMENDED COMPLAINT 

Pursuant to Federal Rule of Civil Procedure 6(b), Defendant Shohei Ohtani (“Ohtani”), by 

and through his undersigned counsel, hereby respectfully moves the Court for an order extending 

the time for Ohtani to respond or otherwise move in response to the operative complaint in this 

action (“Amended Complaint”) [ECF No. 16] to April 14, 2023, without waiving any objection or 

defense, including based on the lack of personal jurisdiction. In support of this motion, Ohtani 

states as follows: 

1. This action was filed on November 15, 2022. See ECF No. 1. Plaintiffs filed the 

operative Amended Complaint on December 16, 2022. 

2. On February 10, 2023, the Court granted Defendants’ Motion for Coordinated 

Briefing Schedule for Responses to the Amended Complaint, ordering that “Any served Defendant 

shall respond to the Amended Complaint on or before April 14, 2023.” ECF No. 49. 

3. On March 1, 2023, Ohtani’s agent accepted service of the Amended Complaint on 

his behalf in Los Angeles. See ECF No. 79. Accordingly, Ohtani respectfully requests the same 

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extension afforded pursuant to the Court’s February 10, 2023 Order, allowing the time for Ohtani 

to respond to be extended until April 14, 2023. 

4. Good cause exists for this requested extension. Ohtani only recently retained 

counsel and requires additional time to evaluate the allegations in the Amended Complaint. 

Further, a brief extension will permit Ohtani’s counsel the opportunity to coordinate with counsel 

for other defendants in compliance with the Court’s instruction that “Multiple . . . Defendants shall 

file joint motions with co-parties unless there are clear conflicts of position.” ECF No. 5. 

5. The requested extension will not delay the proceedings. The requested extension 

will make Ohtani’s response deadline consistent with other defendants and allow for a coordinated 

schedule. 

6. Counsel for the parties have met and conferred regarding this motion on March 

22, 2023, and Plaintiffs do not oppose the extension. See S. D. Fla. L. R. 7.1(a)(3). 

7. Through this Motion for Extension, Ohtani does not waive any objection or defense 

that is available to him, including without limitation any defenses related to lack of personal 

jurisdiction. 

CONCLUSION 

WHEREFORE, Ohtani respectfully requests that this Court enter an order extending the 

time for Ohtani to respond or otherwise move in response to the Amended Complaint to April 14, 

2023. 

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CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(a)(3) 

Pursuant to Local Rule 7.1(a)(3), Mr. Soto, counsel for Defendant Ohtani, conferred with 

Mr. Moskowitz, counsel for Plaintiffs, on March 22, 2023. Plaintiffs do not oppose the requested 

extension. 

/s/ Edward Soto 

 Edward Soto (Fla. Bar No. 0265144) 

 Edward.Soto@weil.com 

 Weil, Gotshal & Manges LLP 

 1395 Brickell Avenue, Suite 1200 

 Miami, Florida 33131 

 Telephone: (305) 577-3100 

 Fax: (305) 374-7159 

 Attorneys for Defendant Shohei Ohtani

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CERTIFICATE OF SERVICE

I hereby certify that on March 22, 2023, I electronically filed the foregoing with the Clerk 

of the Court for the United States District Court for the Southern District of Florida by using the 

CM/ECF system, which sent notification of such filing to all CM/ECF participants. 

/s/ Edward Soto 

 Edward Soto (Fla. Bar No. 0265144) 

 Edward.Soto@weil.com 

 Weil, Gotshal & Manges LLP 

 1395 Brickell Avenue, Suite 1200 

 Miami, Florida 33131 

 Telephone: (305) 577-3100 

 Fax: (305) 374-7159 

 Attorneys for Defendant Shohei Ohtani 

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