UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA

RICCARDO SILVA, 

Plaintiff, 

vs. 

MOBILE BILLBOARDS, INC., et al. 

 Defendants. 

Case No.: 1:22-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 this Court knows, since the inception of this case, Plaintiff has worked 

diligently to identify the John Doe defendants and determine their involvement in the defamation 

campaign alleged in the Complaint. Through his investigation, Plaintiff has discovered that the 

John Doe Defendants have gone to great lengths to conceal their identities and cover up the 

campaign. 

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

participants in the campaign and issued a subpoena to him for the production of documents and 

for a deposition. On two occasions, the deposition was scheduled with the individual’s 

agreement and duly noticed, but the individual canceled at the last moment. Finally, Silva was 

able to take his deposition recently on August 11, 2023. 

3. At the deposition, the individual testified to aspects of the campaign, his 

involvement in it, and the involvement of other individuals in it. 

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4. Based on the deposition, Plaintiff is further investigating the involvement of those 

other parties largely through discovery motions in which third parties have resisted a subpoena 

and the issuance of other subpoenas in order to name at once all parties to the litigation and 

allege their involvement in the defamation campaign. Given the individual’s delay in sitting for 

the deposition, Plaintiff was unable to complete these tasks by today’s date. 

5. Plaintiff requests an extension of up to two (2) months from today’s date to 

amend the pleadings or join parties to allow Plaintiff to obtain that discovery in order to perform 

this investigation and name at once all proper parties and allege their involvement in the 

campaign. 

6. 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. Plaintiff requests that 

the Court’s deadline to file “all motions to amend pleadings or to join parties” be extended to and 

include October 31, 2023. 

7. 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, October 31, 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 August 31, 2023 with Defendant, Mobile Billboards, Inc. counsel in a 

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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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. 

Dated: August 31, 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 

A. SHEILA ORETSKY 

Florida Bar No. 31365 

sheila.oretsky@gtlaw.com 

JOSHUA M. MANDEL 

Florida Bar No. 1031396 

mandelj@gtlaw.com 

FLService@gtlaw.com 

Counsel for Plaintiff Riccardo Silva

 

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CERTIFICATE OF SERVICE 

I hereby certify that on this 31st day of August, 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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