135 San Lorenzo Avenue, Suite 770, Coral Gables, Florida 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 1:22-CV-23074-BLOOM/TORRES

OCTAVIO COLLADO,

COLLECTIVE ACTION

Plaintiff,

vs.

450 NORTH RIVER DRIVE, LLC 

D/B/A KIKI ON THE RIVER 

AND ROMAN JONES,

Defendants.

______________________________/

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO 

DEFENDANTS’ MOTION FOR SANCTIONS PURSUANT TO 28 U.S.C. §1927

Brian H. Pollock, Esq. and FairLaw Firm, pursuant to Local Rule 7.1 and lack of 

opposition, request the Court to grant an extension of time to file their Response in Opposition to 

Defendants’ Motion for Sanctions Pursuant to 28 U.S.C. §1927, as follows:

1. On January 8, 2024, the Court granted the undersigned’s request to withdraw as 

counsel upon being discharged by Plaintiff, Octavio Collado, in recognition of Florida Bar Rule 4-

1.16(a). [ECF No. 241.]

2. Several days after the Court determined that Defendants could not proceed with

the Motion for Rule 11 Sanctions directed at the undersigned and his law firm [ECF No. 241],

Defendants filed a Motion for Sanctions against the undersigned and his law firm, this time 

pursuant to 28 U.S.C. §1927 and the Court’s inherent authority [ECF No. 243].

3. Due to the detailed factual nature of the motion, the legal issues, and the need 

undersigned’s need to consult with Ethics Hotline for The Florida Bar about certain issues related 

Case 1:22-cv-23074-BB Document 246 Entered on FLSD Docket 01/25/2024 Page 1 of 2
135 San Lorenzo Avenue, Suite 770, Coral Gables, Florida 33146

TEL 305.230.4884 FAX 305.230.4844

www.fairlawattorney.com

to the pending Motion, the undersigned requests an additional 14 days from January 26, 2024, 

within which to file a Response.

4. Pursuant to Fed. R. Civ. P. 6(b)(1) “When an act may or must be done within a 

specified time, the court may, for good cause, extend the time: (A) with or without motion or notice 

if the court acts, or if a request is made, before the original time or its extension expires.”

5. This Court has the power to “control the disposition of the causes on its docket with 

economy of time and effort for itself, for counsel and for litigants.” Landis v. North American Co., 299 

U.S. 248, 254 (1936); also see Clinton v. Jones, 520 U.S. 681, 706-707 (1997).

6. The undersigned conferred with defense counsel, who did not oppose the 2-week 

extension of time requested above.

WHEREFORE Brian H. Pollock, Esq. and FairLaw Firm respectfully request the Court to grant 

an extension until February 9, 2024 (14 days), to file their Response to the pending Motion.

LOCAL RULE 7.1 CERTIFICATION

Counsel for the movant conferred with all parties or non-parties who may be affected by 

the relief sought in the motion in a good faith effort to resolve the issues raised in the motion and 

represents that defense agreed to the relief requested above.

Respectfully submitted this 25th day of January 2024,

Brian H. Pollock, Esq.

Brian H. Pollock, Esq.

Fla. Bar No. 174742

brian@fairlawattorney.com

FAIRLAW FIRM

135 San Lorenzo Avenue

Suite 770

Coral Gables, FL 33146

Tel: 305.230.4884

Former Counsel for Plaintiff(s)

Case 1:22-cv-23074-BB Document 246 Entered on FLSD Docket 01/25/2024 Page 2 of 2