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IN THE UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

NELSON FERNANDEZ, 

Case No. 9:22-cv-81512-AMC

Plaintiff,

v.

LITE USA HOLDINGS, INC.

d/b/a LITE STORE USA,

a Florida for-profit corporation,

Defendant.

________________________________/

DEFENDANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO RESPOND TO PLAINTIFF’S COMPLAINT

Defendant, Lite USA Holdings, Inc. d/b/a Lite Store USA (“Defendant”), 

by and through its undersigned counsel, respectfully moves for an extension of 

time, up to and including November 16, 2022, to respond to Plaintiff’s Complaint, 

and states the following in support: 

1. On September 29, 2022, Plaintiff filed the Complaint. (Doc. 1).

2. Defendant was served on October 5, 2022, and, as such, Defendant’s 

deadline to respond to Plaintiff’s Complaint is currently October 26, 2022. 

3. Defendant only recently retained the undersigned counsel in this matter. 

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4. Defendant and the undersigned counsel are in the process of reviewing the 

issues raised in Plaintiff’s Complaint and gathering information relevant to 

the response and defense of this matter. 

5. For the foregoing reasons, Defendant respectfully requests additional time 

to file its response to Plaintiff’s Complaint. 

6. Defendant has conferred with Plaintiff’s counsel regarding the extension of 

time to respond to the Complaint, as requested herein, and Plaintiff has no 

objection to the requested extension.

MEMORANDUM OF LAW

 The Court may grant an enlargement of time for good cause shown when 

the request is made before the original time expires. Fed. R. Civ. P. 6(b).

Defendant’s request for an extension is made in good faith and does not prejudice 

Plaintiff. In fact, Plaintiff agrees to the proposed extension. Permitting the 

extension will enable Defendant to develop a response to the allegations in the 

Complaint following analysis of the relevant files and possibly discuss early 

resolution of the case. For these reasons, Defendant requests that the Court extend 

the deadline to respond to the Complaint.

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LOCAL RULE 7.1(a)(3) CERTIFICATION

Counsel for Defendant hereby certifies that she has conferred with Plaintiff’s 

counsel regarding this motion and that Plaintiff does not oppose the relief 

requested herein. 

WHEREFORE, Defendant, Lite USA Holdings, Inc. d/b/a Lite Store USA, 

respectfully requests an extension of time, up to and including November 16, 2022, 

to respond to Plaintiff’s Complaint.

Dated this 25th day of October, 2022. 

Respectfully submitted,

SPIRE LAW, PLLC

2572 W. State Road 426, Suite 2088

Oviedo, Florida 32765

By: /s/ Alyssa Castelli

Alyssa Castelli

Florida Bar No. 1032306 

Jesse I. Unruh, Esq.

Florida Bar No. 93121

alyssa@spirelawfirm.com 

jesse@spirelawfirm.com 

marcela@spirelawfirm.com

filings@spirelawfirm.com

Attorneys for Defendant

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CERTIFICATE OF SERVICE

I hereby certify that on this 25th day of October 2022, the foregoing was 

electronically filed through the CM/ECF system, which will send a notice of 

electronic filing to Plaintiff’s counsel, Roderick V. Hannah, Esq., RODERICK V. 

HANNAH, ESQ., P.A., 4800 N. Hiatus Road, Sunrise, FL 33351, at 

rhannah@rhannahlaw.com, and Plaintiff’s co-counsel, Pelayo M. Duran, Esq. 

LAW OFFICE OF PELAYO DURAN, P.A., 4640 N.W. 7th Street, Miami, FL 33126-

2309, at duranandassociates@gmail.com. 

/s/ Alyssa Castelli 

 Attorney

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