Case 1:13-cv-22131-JLK Document 14 Entered on FLSD Docket 08/29/2013 Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION CASE NO.: 1:13-cv-22131-JLK SEGUROS UNIVERSALES, S.A., a Guatemalan anonymous society, FIANZAS UNIVERSALES, S.A. n/k/a ASEGURADORA FIDELIS, S.A., a Guatemalan anonymous society, and ORDENADORES, S.A., a Guatemalan anonymous society, v. Plaintiffs,

MICROSOFT CORPORATION, a Washington corporation, Defendant. _______________________________________/ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO FIRST AMENDED COMPLAINT Defendant Microsoft Corporation (Microsoft) hereby moves for an Order enlarging the time by which it must file its response to Plaintiffs First Amended Complaint, [D.E. 13], up to and including September 20, 2013, based upon the following: 1. Plaintiffs initial Complaint (the Complaint) alleged Racketeering,

Constructive Fraud, Abuse of Process and Unjust Enrichment against Microsoft. [D.E. 1]. 2. On August 5, 2013, Microsoft filed its Motion to Dismiss Complaint for Damages

and Injunctive Relief (the Motion to Dismiss), [D.E. 10]. 3. On August 22, 2013, Plaintiffs filed a Motion for Enlargement of Time to

Respond to Microsofts Motion to Dismiss, requesting a thirty (30) day extension of time to file the response. [D.E. 11]. On August 23, 2012, this Court granted Plaintiffs motion, [D.E. 12].

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4.

Instead of filing a response to Microsofts Motion to Dismiss, Plaintiffs, on

August 26, 2013, filed a First Amended Complaint, [D.E. 13], alleging modified counts for Rackeetering and Unjust Enrichment, and including a new cause of action for Fraud. 5. Pursuant to Rule 15 of the Federal Rules of Civil Procedure, Microsofts response

to the First Amended Complaint is due to be filed on September 9, 2013. 6. Due to the impending holiday for which the undersigned counsel has pre-arranged

travel plans, as well as the undersigned counsels pre-existing commitments and case obligations in other matters, Microsoft respectfully seeks a brief enlargement of time up to and including Friday, September 20, 2013, to respond to the First Amended Complaint. 7. This motion is filed in good faith and not for purposes of delay. Under Fed. R.

Civ. P. 6(b), this Court is authorized to extend the period for any such filing for good cause and has the discretion to grant such relief. See In re Trasylol Products Liability Litigation-MDL1928, No. 08MD01928, 2011 WL 5419068, at *4 (S.D. Fla. Aug. 31, 2011). Microsoft respectfully submits that the foregoing circumstances demonstrate good cause for the enlargement of time sought herein.

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Certificate Pursuant to Local Rule 7.1(a) The undersigned counsel certifies, in compliance with Local Rule 7.1(a), that he has conferred in good faith with counsel for Plaintiffs, Mr. Bobadilla, as to the relief requested in the instant motion, and that Plaintiffs do not oppose Microsofts request for extension of time sought herein. WHEREFORE, Microsoft respectfully requests this Court to enlarge the time by which Microsoft must file its response to the First Amended Complaint up to and including September 20, 2013. Dated: August 29, 2013 Respectfully submitted, GREENBERG TRAURIG, P.A. Attorneys for Defendant 333 Avenue of the Americas Miami, Florida 33131 Telephone: (305) 579-0500 Facsimile: (305) 579-0717 E-mail: gonzalezr@gtlaw.com E-mail: rodriguezjo@gtlaw.com By: /s/ Ricardo A. Gonzalez HILARIE BASS Florida Bar No. 334243 RICARDO A. GONZALEZ Florida Bar No. 0691577 JONATHAN J. RODRIGUEZ Florida Bar No. 70431

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CERTIFICATE OF SERVICE I hereby certify that on August 29, 2013, 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 or pro se parties identified on the attached Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or via First Class U.S. Mail for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. /s/ Ricardo A. Gonzalez