On September 06, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Alfonso, Carlos,
and
Caremax Inc.,
Clinica Las Americas, Inc.,
Rodriguez, Luis L,
for Other Civil Complaint
in the District Court of Miami-Dade County.
Preview
Filing # 135769548 E-Filed 10/01/2021 03:51:20 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CARLOS ALFONSO, on all others
similarly situated under 29 U.S.C. § 216(b),
Plaintiff,
v. Case No. 2021-020591-CA-01
CLINICA LAS AMERICAS, INC.,
CAREMAX, INC., and
LUIS L. RODRIGUEZ,
Defendants.
__ /
DEFENDANTS’ UNOPPOSED JOINT MOTION FOR
EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendants, CLINICA LAS AMERICAS, INC., CAREMAX, INC., and LUIS L.
RODRIGUEZ (collectively the “Defendants”), by and through their respective undersigned
counsel and pursuant to Florida Rule of Civil Procedure 1.090(b), hereby file this Unopposed Joint
Motion for Extension of Time to Respond to Plaintiff’s Complaint, and state the following
grounds:
1. The Defendants’ response to the Complaint is currently due on or before October
4, 2021.
2. Respective undersigned counsel for the Defendants have just recently been engaged
in this matter and require additional time to review and investigate the allegations and claims set
forth in the Complaint.
3. As a result, undersigned counsel respectfully requests an extension of fourteen (14)
days in which to file the Defendants’ respective response(s) to the Complaint – i.e.,Monday,
October 18, 2021.
4. This Motion is made in good faith and not for the purpose of unnecessary delay.
1
5. Defendants’ counsel has conferred with Plaintiff’s counsel regarding the relief
sought herein, and Plaintiff’s counsel does not oppose said relief.
Dated: October 1, 2021 Respectfully submitted,
DLA PIPER LLP (US) SMGQ LAW
By: /s/ Ryan O’Quinn By: /s/ Chad K. Lang
Ryan D. O’Quinn (FBN: 513857) Chad K. Lang (FBN: 156922)
200 South Biscayne Blvd., Suite 2500 201 Alhambra Circle, Suite 1205
Miami, Florida 33131 Coral Gables, FL 33134
Tel: 305.423.8553 Tel: 305.377.1000
Fax: 305.675.0807 Fax: 855.327.0391
ryan.oquinn@dlapiper.com clang@smgqlaw.com
Counsel for Caremax, Inc. Counsel for Clinica Las Americas, Inc. and
Luis L. Rodriguez
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 1, 2021, I electronically filed the foregoing
document with the Clerk of the Court using the e-Filing Portal. I also certify that the foregoing
document is being served this day on all counsel of record via e-Service generated by the e-Filing
Portal.
/s/ Ryan O’Quinn
Ryan D. O’Quinn
2
Document Filed Date
October 01, 2021
Case Filing Date
September 06, 2021
Category
Other Civil Complaint
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Filing # 135769548 E-Filed 10/01/2021 03:51:20 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CARLOS ALFONSO, on all others similarly situated under 29 U.S.C. § 216(b), Plaintiff, v. Case No. 2021-020591-CA-01 CLINICA LAS AMERICAS, INC., CAREMAX, INC., and LUIS L. RODRIGUEZ, Defendants. __ / DEFENDANTS’ UNOPPOSED JOINT MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendants, CLINICA LAS AMERICAS, INC., CAREMAX, INC., and LUIS L. RODRIGUEZ (collectively the “Defendants”), by and through their respective undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090(b), hereby file this Unopposed Joint Motion for Extension of Time to Respond to Plaintiff’s Complaint, and state the following grounds: 1. The Defendants’ response to the Complaint is currently due on or before October 4, 2021. 2. Respective undersigned counsel for the Defendants have just recently been engaged in this matter and require additional time to review and investigate the allegations and claims set forth in the Complaint. 3. As a result, undersigned counsel respectfully requests an extension of fourteen (14) days in which to file the Defendants’ respective response(s) to the Complaint – i.e.,Monday, October 18, 2021. 4. This Motion is made in good faith and not for the purpose of unnecessary delay. 1 5. Defendants’ counsel has conferred with Plaintiff’s counsel regarding the relief sought herein, and Plaintiff’s counsel does not oppose said relief. Dated: October 1, 2021 Respectfully submitted, DLA PIPER LLP (US) SMGQ LAW By: /s/ Ryan O’Quinn By: /s/ Chad K. Lang Ryan D. O’Quinn (FBN: 513857) Chad K. Lang (FBN: 156922) 200 South Biscayne Blvd., Suite 2500 201 Alhambra Circle, Suite 1205 Miami, Florida 33131 Coral Gables, FL 33134 Tel: 305.423.8553 Tel: 305.377.1000 Fax: 305.675.0807 Fax: 855.327.0391 ryan.oquinn@dlapiper.com clang@smgqlaw.com Counsel for Caremax, Inc. Counsel for Clinica Las Americas, Inc. and Luis L. Rodriguez CERTIFICATE OF SERVICE I HEREBY CERTIFY that on October 1, 2021, I electronically filed the foregoing document with the Clerk of the Court using the e-Filing Portal. I also certify that the foregoing document is being served this day on all counsel of record via e-Service generated by the e-Filing Portal. /s/ Ryan O’Quinn Ryan D. O’Quinn 2