Case 0:11-cv-62644-RNS Document 45 Entered on FLSD Docket 10/17/2012 Page 1 of 3

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA Case No. 0:11-Civ-62644-RNS __________________________________________ CARLOS ZELAYA, individually, and GEORGE GLANTZ, individually and as trustee of the GEORGE GLANTZ REVOCABLE TRUST, for themselves and on behalf of all those persons similarly situated, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant. __________________________________________/ JOINT MOTION FOR EXTENSION OF TIME TO FILE PROPOSED ORDER SCHEDULING MEDIATION Plaintiffs Carlos Zelaya, individually, and George Glantz, individually and as trustee of the George Glantz Revocable Trust (collectively, Plaintiffs) and Defendant United States of America, respectfully move this Court for a two-week extension of time to October 30, 2012, to file a Proposed Order Scheduling Mediation. In further support of their motion, Plaintiffs and Defendant respectfully state as follows: 1. On December 13, 2011, Plaintiffs filed this action against Defendant United

States of America. 2. On March 21, 2012, the Court entered a Scheduling Order which set various

deadlines, including a September 17, 2012 deadline to file a Proposed Order Scheduling Mediation.

Case 0:11-cv-62644-RNS Document 45 Entered on FLSD Docket 10/17/2012 Page 2 of 3

3.

On September 7, 2012, the Court entered an Order granting in part and denying in

part Defendants motion to dismiss Plaintiffs Complaint. 4. On September 19, 2012, the Court granted the parties Joint Motion for Extension

of Time to File Proposed Order Scheduling Mediation and set a deadline of October 17, 2012. 5. The parties have engaged in discussions regarding mediation and respectfully

request a brief two-week extension of time for the parties to agree on a mediator in order to file their Proposed Order Scheduling Mediation. 6. The deadline to complete mediation is June 3, 2013. The parties are not

requesting an extension of this deadline. WHEREFORE, the parties respectfully request a two-week extension of time to file their Proposed Order Scheduling Mediation, up to October 30, 2012, and for such other relief that the Court deems just and reasonable.

October 17, 2012

Respectfully submitted, KACHROO LEGAL SERVICES, P.C. By: /s/ Brandon R. Levitt Brandon R. Levitt (FBN 30471) Dr. Gaytri D. Kachroo (admitted pro hac) Kachroo Legal Services, P.C. 219 Concord Avenue Cambridge, MA 02138 (617) 864-0755 (617) 864-1125 (Fax) Attorneys for named plaintiffs

Case 0:11-cv-62644-RNS Document 45 Entered on FLSD Docket 10/17/2012 Page 3 of 3

CERTIFICATE OF SERVICE I, Brandon R. Levitt, hereby certify that on October 17, 2012, a true and correct copy of the foregoing was served on all parties of record through the Courts CM/ECF system. /s/ Brandon R. Levitt Brandon R. Levitt