UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 22-cv-62051-AHS

 

HOWARD MICHAEL CAPLAN,

Plaintiff,

vs.

KLRP SERVICES LLC, a Florida Limited Liability 

Company d/b/a LUXURY CARS OF FT. 

LAUDERDALE and BRODY FAMILY 

INVESTMENTS LLC, a Florida Limited Liability 

Company 

Defendant.

/

DEFENDANT, BRODY FAMILY INVESTMENTS, LLC’S UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT

The Defendant, BRODY FAMILY INVESTMENTS, LLC, (“Brody”), through 

counsel and pursuant to Fed.R.Civ.Pro. Rule 6 and Southern District of Florida Local Rule 

7.1(a), moves for the entry of an order extending the time for Brody to file a Response to 

Plaintiff’s Complaint, and as grounds states: 

1. Plaintiff filed his Complaint on November 3, 2022, asserting an ADA 

Violation claim against Defendant, Brody, as owner of the property and a tenant in the 

center (co-defendant KLRP Services, LLC). 

2. Defendant’s response to the complaint is due on or before November 28, 

2022 (immediately after the Thanksgiving Holiday).

3. Counsel for Brody was recently retained to represent the company, is 

involved in settlement discussions with Plaintiff’s attorney, and requires additional time to 

response to the complaint. 

Case 0:22-cv-62051-AHS Document 12 Entered on FLSD Docket 11/22/2022 Page 1 of 3
CAPLAN V. KLRP SERVICES, LLC, ET. AL.

CASE NO.: 22-CV-62051-AHS

MOTION FOR EXTENSION OF TIME 

P AGE | 2

4. Defendant, Brody requests an additional twenty (20) days, through and

including December 19, 2022, to file its response to Plaintiff’s Complaint 

5. Under Federal Rule of Civil Procedure 6(b)(1)(A), a court may extend the 

time for an act to be done for “good cause” when the request is made before the original 

deadline expires.

6. This motion is not made for purposes of delay. 

7. No prejudice will result if the Defendant, Brody’s motion is granted. 

LOCAL RULE 7.1 CERTIFICATION

8. Pursuant to Local Rule 7.1(a)(3), I hereby certify that the undersigned 

conferred in a good faith effort with opposing counsel, Ronald E. Stern, Esq., counsel for 

the Plaintiff, Howard Michael Caplan, who advised he does not oppose the relief 

requested in the motion.

WHEREFORE, the Defendant, BRODY FAMILY INVESTMENTS, LLC, 

respectfully requests entry of an Order extending the deadline for its response to Plaintiff’s 

Complaint, together with such other and further relief as the Court deems just and proper. 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished 

via e-service through this Circuit Court’s E-Portal System this 22nd day of November 2022 

to: Ronald E. Stern, Esq., ronsternlaw@gmail.com, The Advocacy Law Firm, P.A., 1250 

E, Hallandale Beach Blvd., Suite 503, Hallandale Beach, FL 33009. 

Respectfully submitted,

FRANK, WEINBERG & BLACK, P.L.

Attorneys for Defendant

1875 N.W. Corporate Boulevard

Case 0:22-cv-62051-AHS Document 12 Entered on FLSD Docket 11/22/2022 Page 2 of 3
CAPLAN V. KLRP SERVICES, LLC, ET. AL.

CASE NO.: 22-CV-62051-AHS

MOTION FOR EXTENSION OF TIME 

P AGE | 3

Suite 100

Boca Raton, FL 33431

Telephone: (561) 989-0700

Facsimile: (954) 474-9850

Email: rslatoff@fwblaw.net

cmirabile@fwblaw.net

twolosh@fwblaw.net 

By: /s/

Robert T. Slatoff

Fla. Bar No. 816116

Constantina Alexandrou Mirabile

Fla. Bar No. 90853

Case 0:22-cv-62051-AHS Document 12 Entered on FLSD Docket 11/22/2022 Page 3 of 3