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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-81367-CIV-CANNON

NELSON FERNANDEZ, 

Plaintiff,

vs.

KOKO ATLANTIC LLC, d/b/a

KOKONUTS DELRAY BEACH, a 

Florida limited liability company, 

Defendant.

__________________________________/ 

PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME TO

RESPOND TO DEFENDANT’S MOTION TO QUASH SERVICE OF PROCESS

Plaintiff NELSON FERNANDEZ, through undersigned counsel, moves the Court, on an 

unopposed basis, for a two-week extension of time – until November 10, 2022– to file his response 

to Defendant’s Motion to Quash Service of Process [ECF No. 6] on the following grounds: 

 1. Plaintiff’s response to Defendant’s Motion to Quash Service of Process is presently 

due October 27, 2022. 

2. Plaintiff requests a two-week extension of time to allow his counsel sufficient time 

to prepare and file Plaintiff’s response to Defendant’s Motion because of undersigned counsel’s 

various scheduling conflicts and pending deadlines in other cases, which will not provide counsel 

with sufficient time to fully research, secure responsive evidence (specifically, an affidavit from 

Plaintiff’s process server), and prepare a responsive memorandum of law to Defendant’s Motion. 

Plaintiff believes that an additional two weeks – until November 10, 2022 – would be sufficient 

time to allow his counsel to prepare Plaintiff’s response memorandum of law. 

Case 9:22-cv-81367-AMC Document 7 Entered on FLSD Docket 10/26/2022 Page 1 of 3
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 3. Based on the foregoing, Plaintiff and his undersigned counsel believe there is good 

cause for the requested two-week extension of time for them to file Plaintiff’s Response to 

Defendant’s Motion to Quash. 

 4. This Motion is not being interposed for purposes of delay, and the requested 

extension, if granted, will not prejudice the parties or the Court. 

WHEREFORE, Plaintiff requests that his Motion be granted and that the deadline for filing 

his response to Defendant’s Motion to Quash Service of Process be extended to November 10, 

2022. A proposed Order granting this Motion is attached as Exhibit “A”. 

LOCAL RULE 7.1 CERTIFICATE

Undersigned counsel have conferred with counsel for the Defendant and is authorized to 

represent to the Court that Defendant and its counsel do not oppose this Motion. 

Respectfully submitted,

RODERICK V. HANNAH, ESQ., P.A. LAW OFFICE OF PELAYO

Counsel for Plaintiff DURAN, P.A. 

4800 North Hiatus Road Co-Counsel for Plaintiff 

Sunrise, FL 33351-7919 4640 N.W. 7th Street

T. 954/362-3800 Miami, FL 33126-2309

954/362-3779 (Facsimile) T. 305/266-9780 

Email: rhannah@rhannahlaw.com 305/269-8311 (Facsimile)

 Email: pduran@pelayoduran.com 

 

 

By____s/ Roderick V. Hannah __ By ___s/ Pelayo M. Duran ______

RODERICK V. HANNAH PELAYO M. DURAN

 Fla. Bar No. 435384 Fla. Bar No. 0146595

Case 9:22-cv-81367-AMC Document 7 Entered on FLSD Docket 10/26/2022 Page 2 of 3
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 26th day of October, 2022, a true and correct of the 

foregoing was electronically filed and served via transmission of Notice of Electronic Filing 

generated by CM/ECF on all counsel or parties of record on the Service List below:

Ashley Elmore Drew, Esq. 

Andrew Kamensky, Esq. 

McMICHAEL TAYLOR GRAY, LLC

3275 West Hillsboro Boulevard, Suite 312 

Deerfield Beach, FL 33442

(404) 474-7149 

adrew@mtglaw.com 

akamensky@mtglaw.com 

Attorneys for Defendant 

KOKO ATLANTIC LLC

d/b/a KOKONUTS

 /s/ Roderick V. Hannah 

 Roderick V. Hannah

Case 9:22-cv-81367-AMC Document 7 Entered on FLSD Docket 10/26/2022 Page 3 of 3