Filing # 101730708 E-Filed 01/15/2020 05:01:05 PM

IN THE CIRCUIT COURT OF THE

ELEVENTH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA

APPELLATE DIVISION
CASE NO. 2019-000219-AP-01
WARREN PERRY

Petitioner,

v.
CITY OF MIAMI,

Respondent.
______________________________/

PETITIONER’S OBJECTION TO JOINT MOTION OF THE RESPONDENT CITY OF

MIAMI AND INTERVENOR MAGIC CITY FOR AN EXTENSION OF TIME IN
WHICH TO FILE THEIR RESPONSE BRIEFS

In response to Respondent City of Miami and Intervenor Magic City’s

request for additional time in which to file their response to the Amended Petition

for Writ of Certiorari, Petitioner, Warren Perry, states the following:

1. Petitioner objects to the joint request for a three-week extension of time

for filing the response briefs of the City of Miami and Magic City.

2. On October 3, 2019, Magic City responded to Petitioner’s request for a

fifteen (15) day extension of time to file an Amended Petition for Writ of

Certiorari with amended appendices in this case, stating that “Magic City

respectfully submits that further extensions would not be in the best

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 interest of the parties or the public and therefore should not be requested

or granted.” The Court thereupon granted Petitioner a ten-day (10)

extension of time.

3. On November 13, 2019, despite Magic City’s own statement that

extensions of time run counter to the interest of the parties and the public,

the City of Miami and Magic City requested an additional sixty-five (65)

days to file their responses. Petitioner did not object to that extraordinary

request.

4. On January 13, 2020, Magic City contacted Petitioner to request a two-

week extension for response briefs due just four days later on January 17,

2020, and Petitioner responded that Petitioner would agree as a

professional courtesy to a one-week extension of time for the filing of

response briefs.

5. The City of Miami and Magic City are now requesting a three-week

extension and Petitioner objects given the record in this case and the

amount of time that has passed.

6. Counsel for Petitioner have other upcoming professional obligations that

have been planned around the January 17, 2020 deadline set over two

months ago in this Court’s November 19, 2019 Order for the City of

Miami and Magic City to file their response briefs.

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7. Petitioner respectfully suggests that the more than two months that the

City of Miami and Magic City have had to complete their response briefs

is more than a reasonable amount of time.

8. For the foregoing reasons, Petitioner would respectfully request that the

Court limit any extension to one week.

Respectfully submitted,

/s/Jean-Luc Adrien
JEAN-LUC ADRIEN
Florida Bar No.: 1015215
MEENA JAGANNATH
Florida Bar No.: 102684
COMMUNITY JUSTICE PROJECT, INC.
3000 Biscayne Boulevard, Suite 106
Miami, Florida 33137
Phone: (305) 907-7697
E-mail:
jeanluc@communityjusticeproject.com
meena@communityjusticeproject.com

_______/djw/________________
David Winker, Esq.
David J. Winker, P.A.
Florida Bar No.: 73148
2222 SW 17th Street
Miami, Fl 33145
Phone: (305) 907-7697
E-mail: dwinker@dwrlc.com

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 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was

served upon the counsel listed below via electronic mail, on January 15, 2020.

/s/ Jean-Luc Adrien

JEAN-LUC ADRIEN
Florida Bar No.: 1015215

SERVICE LIST

Kerri L. McNulty, Esq.

Victoria Méndez, City of Miami Attorney
Office of the City Attorney
444 S.W. 2nd Avenue, Suite 945
Miami, Florida 33130
Primary E-mail: klmcnulty@miamigov.com
Secondary E-mail: mgriffin@miamigov.com

-and-

Joni Armstrong Coffey, Esq.

Eve A. Boutsis, Esq.
Benjamin O. Hedrick, Esq.
Akerman LLP
98 SE 7th St., Suite 1100
Miami, FL 33131-3525
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