On December 18, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Marrapodi, Eugenio,
and
Dragin, Michael,
F O X Intermodal Corp,
Martini International Movers Llc,
for Fraud
in the District Court of Broward County.
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Filing # 71114429 E-Filed 04/23/2018 04:45:40 PM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
EUGENIO MARRAPODI, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO.: CACE15022322 05
vs.
MICHAEL DRAGIN, MARTINI
INTERNATIONAL MOVERS, LLC, a New
Jersey limited liability company, and F.O.X.
INTERMODAL CORP., a New Jersey
corporation;
Defendants.
PLAINTIFF’S THIRD UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE AMENDED COMPLAINT
Plaintiff, Eugenio Marrapodi (“Marrapodi”), by and through undersigned counsel, moves
this Court for an extension of time, through and including May 3, 2018, in which to file
Plaintiff's Amended Complaint, and states as follows:
1. Plaintiff's deadline to file his Amended Complaint is April 23, 2018.
2. Due to the press of business, undersigned counsel is in need of an extension,
through and including May 3, 2018, in which to file his Amended Complaint. Specifically,
undersigned counsel has been preparing for, and attending depositions of key witnesses in the
case styled EEOC vy. SBEEG Holdings, LLC, et al, Case No. 17-21446-cv-
COOKE/GOODMAN, in which undersigned counsel represents fifteen (15) aggrieved Haitian
Kitchen Workers in tandem with the Southern District of Florida Office of the Equal
Employment Opportunity Commission.
3. Furthermore, undersigned counsel’s associate that was preparing the response is
out of the office for the next few days due to a medical emergency.
Page|
The Alderman Law Firm
9999 NE 2nd Ave., Suite 211 ¢ Miami Shores, FL 33138 @ ph. 305.200.5473 @ fax. 305.200.5474
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/23/2018 4:45:40 PM.****4, Undersigned counsel has conferred with Defendant FOX Intermodal Corp.’s
counsel and is authorized to represent that there is no objection to the relief sought.
5. This motion is brought in good faith and not solely for purposes of delay.
6. No party will be prejudiced by the granting of the relief sought.
WHEREFORE, Plaintiff Marrapodi respectfully requests that this Court grant an
extension, through and including May 3, 2018, in which to file Plaintiff's Amended Complaint.
Respectfully submitted,
THE ALDERMAN LAW FIRM
Attorneys for Plaintiff
9999 NE 2nd Avenue, Suite 211
Miami Shores, Florida 33138
Telephone:305-200-5473
Facsimile: 305-200-5474
E-Mail: jalderman@thealdermanlawfirm.com
By: /s/ Troy A. Tolentino
Jason R. Alderman
Florida Bar No. 172375
Troy A. Tolentino
Florida Bar No. 117981
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via
electronic mail to Edward F. MHolodak, Esq. at pleadings@holodakpa.com
Edward@holodakpa.com on this 23" day of April, 2018.
By: /s/ Troy A. Tolentino
Troy A. Tolentino
Page |2
The Alderman Law Firm
9999 NE 2nd Ave., Suite 211 @ Miami Shores, FL 33138 @ ph. 305.200.5473 @ fax. 305.200.5474
Document Filed Date
April 23, 2018
Case Filing Date
December 18, 2015
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Filing # 71114429 E-Filed 04/23/2018 04:45:40 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA EUGENIO MARRAPODI, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO.: CACE15022322 05 vs. MICHAEL DRAGIN, MARTINI INTERNATIONAL MOVERS, LLC, a New Jersey limited liability company, and F.O.X. INTERMODAL CORP., a New Jersey corporation; Defendants. PLAINTIFF’S THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE AMENDED COMPLAINT Plaintiff, Eugenio Marrapodi (“Marrapodi”), by and through undersigned counsel, moves this Court for an extension of time, through and including May 3, 2018, in which to file Plaintiff's Amended Complaint, and states as follows: 1. Plaintiff's deadline to file his Amended Complaint is April 23, 2018. 2. Due to the press of business, undersigned counsel is in need of an extension, through and including May 3, 2018, in which to file his Amended Complaint. Specifically, undersigned counsel has been preparing for, and attending depositions of key witnesses in the case styled EEOC vy. SBEEG Holdings, LLC, et al, Case No. 17-21446-cv- COOKE/GOODMAN, in which undersigned counsel represents fifteen (15) aggrieved Haitian Kitchen Workers in tandem with the Southern District of Florida Office of the Equal Employment Opportunity Commission. 3. Furthermore, undersigned counsel’s associate that was preparing the response is out of the office for the next few days due to a medical emergency. Page| The Alderman Law Firm 9999 NE 2nd Ave., Suite 211 ¢ Miami Shores, FL 33138 @ ph. 305.200.5473 @ fax. 305.200.5474 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 4/23/2018 4:45:40 PM.****4, Undersigned counsel has conferred with Defendant FOX Intermodal Corp.’s counsel and is authorized to represent that there is no objection to the relief sought. 5. This motion is brought in good faith and not solely for purposes of delay. 6. No party will be prejudiced by the granting of the relief sought. WHEREFORE, Plaintiff Marrapodi respectfully requests that this Court grant an extension, through and including May 3, 2018, in which to file Plaintiff's Amended Complaint. Respectfully submitted, THE ALDERMAN LAW FIRM Attorneys for Plaintiff 9999 NE 2nd Avenue, Suite 211 Miami Shores, Florida 33138 Telephone:305-200-5473 Facsimile: 305-200-5474 E-Mail: jalderman@thealdermanlawfirm.com By: /s/ Troy A. Tolentino Jason R. Alderman Florida Bar No. 172375 Troy A. Tolentino Florida Bar No. 117981 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic mail to Edward F. MHolodak, Esq. at pleadings@holodakpa.com Edward@holodakpa.com on this 23" day of April, 2018. By: /s/ Troy A. Tolentino Troy A. Tolentino Page |2 The Alderman Law Firm 9999 NE 2nd Ave., Suite 211 @ Miami Shores, FL 33138 @ ph. 305.200.5473 @ fax. 305.200.5474