Case 1:13-cv-22131-JLK Document 11 Entered on FLSD Docket 08/22/2013 Page 1 of 4

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION

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, Plaintiffs, v. MICROSOFT CORPORATION, a Washington corporation, Defendant.

CASE NO. 1:13-cv-22131-JLK

PLAINTIFFS' MOTION FOR ENLARGEMENT FO TIME TO RESPOND TO DEFENDANT'S MOTION TO DISMISS [D.E. 10] Plaintiffs, SEGUROS UNIVERSALES, S.A., FIANZAS UNIVERSALES, S.A. and ORDENADORES, S.A., by and through undersigned counsel and pursuant to Rule 6(b), Fed.R.Civ.P. and S.D.L.R. 7.1(a)(1), file this Motion for Enlargement of Time to Respond to Defendant's Motion to Dismiss [D.E. 10], and in support thereof states as follows: 1. Plaintiffs' Response to Defendant's Motion to Dismiss [D.E. 10] is due on or

before August 22, 2013. 2. Previously, Defendant requested and was granted a thirty (30) day enlargement of

time to respond to Plaintiffs' Complaint. See Order Granting Enlargement [D.E. 9]. Near the expiration of the enlargement, Defendant filed a voluminous Motion to Dismiss. While the

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Motion is formatted to appear to be within the twenty (20) page limit of S.D.L.R. 7.1(b)(c)(2), it is many pages in excess of the limit. Every citation in the Motion is set forth in compressed (reduced font) single spaced footnotes containing extensive argument, all of which if placed properly in the body of the Motion in the font required by the rules, constitute pages of text in excess of the limit. 3. Due to the volume of Defendant's Motion to Dismiss and the complexity of the

factual and legal issues, and due to undersigned counsel's responsibilities in this and other matters, like Defendant, and despite diligent effort, Plaintiffs require an enlargement of time of thirty (30) days to respond. 4. purpose. 5. Undersigned counsel sought Defendant's consent from it's counsel, Ricardo This Motion is not interposed for purposes of delay or for any other improper

Gonzalez. Mr. Gonzalez conditioned consent on Plaintiffs' agreement to subsequent thirty (30) day enlargements of time for Defendant to respond to pleadings Plaintiffs have not yet filed. The Rules of procedure do not contemplate, and Plaintiffs cannot agree to, wholesale consent for future enlargements without regard to Defendants' showing of good cause. Accordingly, Mr. Gonzalez did not agree to the requested enlargement of time. WHEREFORE, Plaintiffs, SEGUROS UNIVERSALES, S.A., FIANZAS

UNIVERSALES, S.A. and ORDENADORES, S.A., respectfully request an enlargement of time through and including September 20, 2013 to respond to Defendant's Motion to Dismiss [D.E. 10], and for such other and further relief as this Court deems just and proper.

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CERTIFICATE OF GOOD FAITH CONFERENCE Pursuant to S.D.L.R. 7.1(A)(3), undersigned counsel certifies that he has conferred with counsel for Defendant who opposes the relief requested by this motion. Respectfully submitted, THE BOBADILLA LAW FIRM Attorneys for Plaintiffs 20900 NE 30th Avenue, Suite 800 Aventura, FL 33180 Telephone: 786.446.8643 Facsimile: 786.446.8641 By: s/ D. Fernando Bobadilla D. Fernando Bobadilla, Esq. Fla. Bar No. 0136948 fernandob@bobadillafirm.com CERTIFICATE OF SERVICE I hereby certify that on this 22nd day of August 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 below Service List in the manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing. By: s/ D. Fernando Bobadilla, Esq. D. Fernando Bobadilla, Esq.

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SERVICE LIST Hilarie Bass, Esq. Ricardo A. Gonzalez, Esq. Jonathan J. Rodriguez, Esq. GREENBERG TRAURIG, P.A. 333 Avenue of the Americas Miami, Florida 33131 Tel. (305) 579-0500 Facsimile (305) 579-0717 gonzalezr@gtlaw.com rodriguezjo@gtlaw.com Attorneys for Defendant