IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA APPELLATE DIVISION JACOB

PFEFFER, et al., CASE NO.: 14-004 AP Petitioners, vs. CITY OF MIAMI, FLORIDA and WAL-MART STORES EAST, LP, Respondents. / UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO SERVE RESPONSE BRIEF Respondent, Wal-Mart Stores East, LP, by and through its undersigned counsel, hereby files its Motion for Enlargement of Time to Serve its Response Brief and in support states as follows: 1. 2014. 2. On January 9, 2014, the Court issued an Order requiring Respondents Petitioners filed their Petition for Writ of Certiorari on January 2,

to file a response to the Petition for Writ of Certiorari within twenty (20) days of the Order. 3. The undersigned is in need of additional time within which to serve

the Response Brief.

4.

The undersigned has been diligently working on other trial and

appellate matters, and requires an extension of time up to and including February 27, 2014, for proper consultation, evaluation and preparation of the Respondents Brief. 5. delay. 6. The undersigned contacted counsel for Petitioners, Paul C. Savage, This motion is made in good faith and is not intended to interpose

Esq., and is authorized to represent Petitioners do not oppose the relief requested. Respectfully submitted this 22nd day of January, 2014. LYDECKERDIAZ Counsel for Respondent, Wal-Mart Stores East, LP 1221 Brickell Avenue, 19th Floor Miami, Florida 33131 Tel.: (305) 416-3180 Fax: (305) 416-3190 By: s/ Joan Carlos Wizel Joan Carlos Wizel (FBN 37903) E-mail: jcw@lydeckerdiaz.com Mark A. Emanuele (FBN 541834) E-mail: mae@lydeckerdiaz.com Richard Lydecker (FBN 490555) E-mail: rl@lydeckerdiaz.com Manuel A. Diaz (FBN 310514) E-mail: manny@lydeckerdiaz.com

CERTIFICATE OF SERVICE I hereby certify that on this 22th day of January, 2014, a copy of the foregoing as Counsel was sent via e-mail to: Paul C. Savage E-mail: paul@savagelegal.com Law Offices of Paul C. Savage, P.A. 100 Almeria Avenue, Suite 220 Coral Gables, Florida 33134 Attorney for Petitioners John A. Greco E-mail: jagreco@miamigov.com Victoria Mendez E-mail: vmendez@miamigov.com E-mail: law@miamigov.com 44 S.W. 2nd Avenue, Suite 945 Miami, Florida 33130 Attorneys for Respondent City of Miami

By: s/ Joan Carlos Wizel Joan Carlos Wizel (FBN 37903)