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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR

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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR Powered By Docstoc
					                                               IN THE CIRCUIT COURT OF THE
                                               ELEVENTH JUDICIAL CIRCUIT, IN
                                               AND FOR MIAMI-DADE COUNTY,
                                               FLORIDA

                                               APPELLATE DIVISION
JESUS JIMENEZ,

             Appellant,                        CASE NO.: 07-556 AP

v.                                             Lower Tribunal No.: 20-070113-75 5U

MIAMI DADE COUNTY,
a political subdivision,

          Appellee.
___________________________/

                               SECOND
                     MOTION FOR EXTENSION OF TIME

      Appellant, JESUS JIMENEZ, moves this Court for an extension of time to file

the record and initial brief and in support states:

1.    Undersigned counsel represents the appellant through the Eleventh Judicial

      Circuit Put Something Back pro bono project and is withdrawing from the case

      because Put Something Back does not provide pro bono legal representation

      in appellate courts.

2.    To give appellant an opportunity to find other counsel to prosecute this appeal,

      appellant asked for a 30 day extension of time through March 17, 2008 which

      this Court granted.
3.    However, appellant is a U.S. soldier currently stationed in Iraq and, because it

      has become difficult for him to find another lawyer, he respectfully asks that

      this Court grant him an additional 15 days extension of time through April 1,

      2008 to find an appellate attorney to make arrangements for the record and to

      file his initial brief to appeal Miami-Dade County’s finding that his home is

      unsafe and so must be demolished.

4.    This motion is brought in good faith and not for the purposes of harassment or

      delay.

5.    Appellee will not suffer prejudice if this motion is granted. Conversely, the

      Appellant will be gravely prejudiced if this motion is denied.

6.    The undersigned conferred with Appellee’s counsel who does not object to this

      motion.

I HEREBY CERTIFY that a copy of the foregoing was delivered to Andrew Boese
Esq., County Attorney, Miami-Dade County, County Attorney's Office, 111
Northwest First Street, Suite 2810, Miami, Florida 33128by First Class U.S. Mail on
this ______ day of _______, 2008.

                                                      ALAIN LECUSAY, P.A.
                                                 COURTHOUSE PLAZA, STE 610
                                                         28 W. FLAGLER ST.
                                                            MIAMI, FL 33130
                                                              T 305.372.1415

                                                    By:_______________________
                                                                   Alain Lecusay
                                                      Fla. Bar Member No.:715433

				
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