Filing # 101704454 E-Filed 01/15/2020 02:02:05 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA
APPELLATE DIVISION
WARREN PERRY, CASE NO.: 19-219 AP

Petitioner,

vs.

CITY OF MIAMI,

Respondent,

and

MCD MIAMI, LLC, et al.,

Intervenor.
/

JOINT MOTION OF THE CITY OF MIAMI AND MAGIC CITY

FOR AN EXTENSION OF TIME IN WHICH TO FILE
THEIR RESPONSE BRIEFS

The City of Miami and Magic City respectfully request a three-week

extension of time in which to file their Response Briefs in this matter, up to and
including February 7, 2020, upon the following grounds:
1. On November 18, 2019, this Court issued its Order setting the date for
filing the Response Briefs for January 17, 2020.
2. Counsel for the City and for Magic City have had substantial other
professional and personal obligations, including the preparation of briefs in other
matters, since their request to set the due date for the Response Briefs for January
17, 2020.
3. Counsel for the City and for Magic City have conferred and believe

1
51639286;1
that preparation of their Response Briefs will require an additional three weeks, up
to and including February 7, 2020, and seek leave to file by that date.
4. Undersigned has personally conferred with counsel for the Petitioner
regarding the request, who objects to an extension of time longer than one week.
Undersigned counsel has not been made aware of the basis for the objection, but has
indicated that she will rely on Petitioner's counsel to file a response indicating the
basis for objection if thought appropriate.
5. The requested relief is not made for the purpose of undue delay, or for
any other improper purpose. The parties will not be prejudiced by the granting of
the requested relief.
WHEREFORE, the City of Miami and Magic City respectfully request that
this Court grant their Joint Motion for an Extension of Time in which to file their
Response Briefs to February 7, 2020.

Respectfully submitted,

AKERMAN LLP
Counsel for Intervenor Magic City
Three Brickell City Centre
98 Southeast Seventh Street
Suite 1100
Miami, Florida 33131
Telephone: (305) 374-5600
Facsimile: (305) 374-5095

/s/ Joni Armstrong Coffey

Joni Armstrong Coffey – Florida Bar No.: 281646
Eve A. Boutsis - Florida Bar No.: 082538
Benjamin O. Hedrick - Florida Bar No.: 91140
Primary: joni.armstrong.coffey@akerman.com
Primary: eve.boutsis@akerman.com
Primary: benjamin.hedrick@akerman.com
Secondary: maria.y.gonzalez@akerman.com
Secondary: kate.quelch@akerman.com
2
51639286;1
 CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing Joint
Motion, using the Florida Courts E-Filing Portal, and that a true and correct copy
was furnished via Electronic Mail this 15th day of January, 2020, to all parties listed
below.

Victoria Mendez, Esquire Meena Jagannath, Esquire

Kerri L. McNulty, Esquire
klmcnulty@miamigov.com
csantos@miamigov.com
Senior Appellate Counsel
Appellate Division
City of Miami
Office of the City Attorney
Miami Riverside Center (MRC)
444 S.W. 2nd Avenue, Suite 945
Miami, Florida 33130
Telephone: (305) 416-1800
Facsimile: (305) 416-1801
Counsel for Respondent City of Miami
Jean-Luc Adrien, Esquire
meena@communityjusticeproject.com
jeanluc@communityjusticeproject.com
Community Justice Project, Inc.
3000 Biscayne Boulevard, Suite 106
Miami, Florida 33137
Telephone: (305) 907-7697
and
David J. Winker, Esquire
dwinker@dwrlc.com
David J. Winker, P.A.
2222 S.W. 17th Street
Miami, Florida 33145
Telephone: (305) 801-8700
Facsimile: (305) 444-8588
Counsel for Petitioner Warren Perry

/s/ Joni Armstrong Coffey

Joni Armstrong Coffey
Florida Bar Number: 281646

CERTIFICATE OF COMPLIANCE
I HEREBY CERTIFY that this document is printed in Times New Roman
14-point font in compliance with the Florida Rules of Appellate Procedure 9.100(l).
/s/ Joni Armstrong Coffey
Joni Armstrong Coffey
Florida Bar Number: 281646

3
51639286;1