IN THE CIRCUIT COURT OF THE
ELEVENTH JUDICIAL CIRCUIT, IN
AND FOR MIAMI-DADE COUNTY,
Appellant, CASE NO.: 07-556 AP
v. Lower Tribunal No.: 20-070113-75 5U
MIAMI DADE COUNTY,
a political subdivision,
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
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
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
Fla. Bar Member No.:715433