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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 1:21-cv-23103-BLOOM/OTAZO-REYES

CASA EXPRESS CORP, as Trustee of

CASA EXPRESS TRUST,

Judgment Creditor,

v.

BOLIVARIAN REPUBLIC OF 

VENEZUELA,

Judgment Debtor.

/

MOTION TO COMPEL IMPLEADED DEFENDANTS TO PARTICIPATE IN 

DRAFTING JOINT SCHEDULING REPORT AND A PROPOSED SCHEDULING 

ORDER OR, ALTERNATIVELY, MOTION FOR A SCHEDULING CONFERENCE

Plaintiff and Judgment Creditor Casa Express Corp, as Trustee of Casa Express Trust 

(“Plaintiff”), moves to compel the Impleaded Defendants1 to participate in the drafting a joint 

scheduling report and a proposed scheduling order in accordance with this Court’s Civil 

Procedures. Alternatively, Plaintiff moves for a scheduling conference with the Court. 

1. This Court’s Civil Procedures require parties to “confer, prepare and file a joint 

scheduling report and a proposed scheduling order” once the defendants have appeared in the 

action. 

2. In this action, the Gorrin Entities appeared through counsel nearly two years ago 

on November 4, 2021. ECF No. [35]. Gorrin appeared through counsel approximately a year later 

on November 1, 2022. ECF No. [102]. 

1 “Impleaded Defendants” collectively refer to Raul Gorrin Belisario (“Gorrin”), and his 

entities: Posh 8 Dynamic Inc., Planet 2 Reaching Inc., RIM Group Investments Inc., RIM Group 

Investments I Inc., RIM Group Investments II Inc., and RIM Group Investments III Inc.

(collectively, “Gorrin Entities”). 

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3. On October 18, 2023, Plaintiff conferred with counsel to the Impleaded Defendants 

to attempt drafting a joint scheduling report and a proposed scheduling order in accordance with 

the Court’s Civil Procedures. 

4. However, counsel to the Impleaded Defendants objected to jointly drafting a 

scheduling report and a proposed scheduling order contending that it would be “premature” by 

virtue of the motions for judgment on the pleadings, ECF Nos. [231, 232], that they filed last week. 

5. But the Civil Procedures plainly require the parties to prepare and file a joint 

scheduling report with a proposed scheduling order “[o]nce the defendant[s] appear[s] in the 

action[.]” As explained above, the Gorrin Entities appeared in this action nearly two years ago,

and Gorrin appeared nearly a year ago. Therefore, their recently filed motions do not justify 

postponing entry of a scheduling order in this action. 

6. For this reason, Plaintiff respectfully requests that the Court compel the Impleaded 

Defendants to participate in the drafting of a joint scheduling report and a proposed scheduling 

order in accordance with the Court’s Civil Procedures. Alternatively, Plaintiff respectfully requests 

that the Court hold a scheduling conference at its earliest convenience. 

WHEREFORE, Plaintiff and Judgment Creditor Casa Express Corp, as Trustee of Casa 

Express Trust respectfully requests that the Court compel the Impleaded Defendants to comply 

with the Court’s Civil Procedures. Alternatively, Plaintiff respectfully requests that the Court hold 

a scheduling conference at its earliest convenience.

Dated: October 19, 2023 Respectfully submitted,

GAMARDO, P.A.

1200 Brickell Avenue, Suite 750 

Miami, Florida 33131

Tel: (305)542-6626

/s/ Andres Gamardo

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Andres Gamardo, Esq. 

Florida Bar No.: 1021165

Email: agamardo@gamardolaw.com

Attorney for Casa Express Corp, as Trustee 

of Casa Express Trust

CERTIFICATE OF SERVICE

I hereby certify that on October 19, 2023, I authorized the electronic filing of the foregoing 

with the Clerk of the Court using the CM/ECF system. 

By: /s/ Andres Gamardo

 Andres Gamardo, Esq.

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