UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

RICCARDO SILVA, 

Plaintiff, 

vs. 

MOBILE BILLBOARDS, INC., et al. 

 Defendants. 

Case No.: 22-cv-24262-Altman/Reid 

 

PLAINTIFF RICCARDO SILVA’S UNOPPOSED MOTION TO EXTEND 

TIME TO AMEND PLEADINGS OR TO JOIN CERTAIN PARTIES 

Plaintiff Riccardo Silva (“Plaintiff”), pursuant to Rule 15(a)(2) of the Federal Rules of 

Civil Procedure and Southern District of Florida Local Rule 7.1(a)(1)(J), respectfully moves the 

Court for an Order extending time to amend pleadings or to join certain parties. In support 

thereof, Plaintiff states as follows: 

1. As Plaintiff has previously informed this Court, since he filed this case alleging a 

malicious, defamatory campaign against him by John Doe Defendants, he has worked diligently 

to identify those defendants and determine their involvement in the scheme. Plaintiff’s 

investigation revealed that the John Doe Defendants went to great lengths to conceal their 

identities and cover up the scheme, including by the use of phony names, phony email and street 

addresses, and the use of technology to cover their tracks. 

2. Despite the active concealment, Plaintiff has positively identified one of those 

John Does, who is a man whose place of residence is Alexandria, Virginia, and who was a key 

participant in the scheme. 

3. Since identifying that John Doe, Plaintiff has engaged in settlement discussions 

with and sought to obtain information from him about other John Doe(s) involved in the scheme 

Case 1:22-cv-24262-RKA Document 39 Entered on FLSD Docket 07/21/2023 Page 1 of 5
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and the nature of their involvement, but, to date, Plaintiff has been unable to reach resolution or 

to obtain information from him. 

4. Plaintiff intends to name him as a defendant in a first amended complaint which 

Plaintiff intends to file if resolution cannot be reached forthwith. 

5. If he is named, it will be necessary to take party discovery on that John Doe to 

obtain information about the other John Doe(s) involved in the scheme in order to fully 

understand the nature of their participation in the scheme. Plaintiff intends to take that discovery 

as soon as allowable once that John Doe is named in a first amended complaint. 

6. Plaintiff is confident that that discovery, along with other third-party discovery, 

will be sufficient to confirm the nature of the participation of the other John Doe(s) involved in 

the scheme. After having obtained that discovery, Plaintiff intends to name those other John 

Doe(s) in a second amended complaint. 

7. The current due date set by the Court to amend the pleadings or join parties is July 

31, 2023, [ECF No. 32]. 

8. Plaintiff requests an extension of four (4) months to amend the pleadings or join 

parties to allow Plaintiff to obtain that discovery in order to fully understand the nature of the 

participation of the other John Doe(s). 

9. To be clear, Plaintiff intends to file a first amended complaint naming the John 

Doe Plaintiff has positively identified as a defendant if Plaintiff and that John Doe are unable to 

reach resolution prior to the current July 31, 2023 deadline. But Plaintiff requests the instant 

extension of the Court’s deadline to obtain information from that John Doe and other third-party 

discovery in order to fully understand the nature of the participation of the other John Doe(s) 

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sufficient to name them in a second amended complaint. Therefore, good cause exists to grant 

the extension. 

10. To date, no Defendant has filed a responsive pleading to the Complaint.1 The 

instant motion is being made in good faith and for no improper purpose. Further, the requested 

extension will not prejudice any of the parties, nor will it unduly delay the proceedings. Plaintiff 

requests that the Court’s July 31, 2023, deadline to file “all motions to amend pleadings or to 

join parties” be extended to and include November 30, 2023. 

11. Prior to filing the instant motion, Plaintiff spoke with counsel for Defendant 

Mobile Billboard, who informed Plaintiff that Mobile Billboard has no objection to this motion. 

WHEREFORE, Plaintiff Riccardo Silva respectfully requests that this Court enter an 

Order extending the time by which the parties are to file “all motions to amend pleadings or to 

join parties” up to and including Thursday, November 30, 2023, together with such other and 

further relief the Court deems just and proper. 

CERTIFICATE OF GOOD FAITH CONFERENCE 

 Pursuant to Local Rule 7.1(a)(3), undersigned counsel for Plaintiff certifies he 

conferred via email on July 20, 2023 with Defendant, Mobile Billboards, Inc. counsel in a good 

faith effort to resolve the issue raised in this motion and was able to secure their agreement to the 

relief sought herein as detailed above. 

 

1

 Currently, the only named defendant (i.e., the only non-John Doe defendant) is Defendant Mobile 

Billboards, Inc., who provided the mobile billboard truck on which the defamatory content was published. 

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Dated: July 21, 2023. Respectfully submitted, 

 

By: /s/ Benjamin Greenberg 

GREENBERG TRAURIG, P.A. 

333 S.E. 2nd Avenue, Suite 4400 

Miami, Florida 33131 

Telephone: (305) 579-0570 

Facsimile: (305) 961-5702 

THOMAS R. HEISLER 

Florida Bar No. 1029852 

heislert@gtlaw.com 

BENJAMIN GREENBERG 

Florida Bar No. 192732 

greenbergb@gtlaw.com 

JOSHUA M. MANDEL 

Florida Bar No. 1031396 

mandelj@gtlaw.com 

cruzm@gtlaw.com 

fernandezf@gtlaw.com 

FLService@gtlaw.com 

Counsel for Plaintiff Riccardo Silva

 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 21st day of July, 2023, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document 

is being served this day on all counsel of record via transmission of Notices of Electronic Filing 

generated by CM/ECF. 

/s/ Benjamin Greenberg 

 BENJAMIN GREENBERG 

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