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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 1 of 7
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`Appeal No. 23-13156-F
`In the United States Court of
`Appeals for the Eleventh Circuit
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`ATHOS OVERSEAS LIMITED CORP.,
`Appellant,
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`v.
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`YOUTUBE, INC., YOUTUBE, LLC, and
`GOOGLE, LLC,
`Appellees.
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`On Appeal from the United States District Court
`for the Southern District of Florida
`Case No. 21-cv-21698-DPG
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`APPELLANT’S UNOPPOSED MOTION FOR EXTENSION OF TIME
`TO FILE REPLY BRIEF
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`Omar Ortega
`Rey Dorta
`Rosdaisy Rodriguez
`Dorta & Ortega, PA
`Attorneys for Appellant
`3860 SW 8th Street, PH
`Coral Gables, Florida 33134
`Phone: 305-461-5454
`Email: oortega@dortaandortega.com
`Email: rdorta@dortaandortega.com
`Email:rrodriguez@dortaandortega.com
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 2 of 7
`Athos Overseas Limited Corp. v. YouTube, Inc., et. al., No. 23-13156-F (11th Cir.)
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`Eleventh Circuit Rule 26.1 Certificate of Interested Persons
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`Athos Overseas Limited Corp. (Appellant)
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`Byrd, Dylan (counsel for Appellee)
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`Cine Estelar, Inc.
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`Cine Nostalgia, Inc.
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`Coulter, David T (counsel for Appellee)
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`Dorta & Ortega, P.A. (counsel for Appellant)
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`Dorta, Reinaldo (counsel for Appellant)
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`Gente de Cine, S.A.
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`Google LLC (Appellee)
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`Gorman, Nathalie M. (counsel for Appellee)
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`Green Anaba, Ariel C. (counsel for Appellee)
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`Hartman, Catherine R. (counsel for Appellee)
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`Li, Luis (counsel for Appellee)
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`Ortega, Omar (counsel for Appellant)
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`Reed, Jenea M. (counsel for Appellee)
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`Rodriguez, Rosdaisy (counsel for Appellant)
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`Shapiro, Jay B (counsel for Appellee)
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`Stearn Weaver Miller Weisller Alhadeff & Sitterson, P.A. (counsel for Appellee)
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`Templeton, Trevor (counsel for Appellee)
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`C-1 of 2
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 3 of 7
`Athos Overseas Limited Corp. v. YouTube, Inc., et. al., No. 23-13156-F (11th Cir.)
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`Top Entertainment Products, Inc.
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`Top Products Investments, Inc.
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`Tuttle, Eric (counsel for Appellee)
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`Vasallo, Carlos
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`Willen, Brian M (counsel for Appellee)
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`Wilson Sonsini Goodrich & Rosati (counsel for Appellee)
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`Yen, Lucy (counsel for Appellee)
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`Youtube, LLC (Appellee)
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`Appellant certifies that no publicly held corporation owns 10% or more of its
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`stock.
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`C-2 of 2
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 4 of 7
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`UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE
`APPELLANT’S REPLY BRIEF
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`Appellant, Athos Overseas Limited Corp., pursuant to Federal Rule of
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`Appellate Procedure 26(b) and Eleventh Circuit Rule 31-2, respectfully requests a
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`ten-day extension of time to serve its Reply Brief, and in support thereof states as
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`follows:
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`1. Appellant filed its Initial Brief on December 6, 2023.
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`2. On February 5, 2024, Appellees filed their Brief.
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`3. Appellant’s Reply Brief is currently due on February 26, 2024.
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`4. The undersigned counsel is in the midst of preparing for a final evidentiary
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`hearing in an arbitration before the American Arbitration Association
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`commencing on February 19, 2024, and scheduled to conclude on February
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`21, 2024.
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`5. The undersigned counsel has also been preparing for an all-day evidentiary
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`hearing being held on February 16, 2024, in the matter of In re: The marriage
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`of Keith Kurland and Evelyn C. Kurland, Case NO. FMCE 18-001932 (33).
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`6. Therefore, the undersigned counsel respectfully requests a ten-day extension
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`of time to file Appellant’s Reply Brief on March 7, 2024.
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`7. Appellant’s counsel has conferred with Appellees’ counsel regarding the
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`extension requested and Appellees’ counsel has no objection to the
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`enlargement of time.
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 5 of 7
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`8. This request is made for good cause, in good faith, and not for the purpose of
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`delaying resolution of this appeal.
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`WHEREFORE, Appellant respectfully requests this Court grants an
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`extension of time until March 7, 2024, to file its Reply Brief.
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`Respectfully submitted,
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`DORTA & ORTEGA, P.A.
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`/s/ Omar Ortega_________________
`Omar Ortega, Esq.
`Florida Bar No.095117
`Rey Dorta, Esq.
`Florida Bar No. 0084920
`Rosdaisy Rodriguez, Esq.
`Florida Bar No. 0112710
`3860 SW 8th Street, PH
`Coral Gables, Florida 33134
`Phone: (305)461-5454
`Facsimile: (305)461-5226
`Email: oortega@dortaandortega.com
`Email: rdorta@dortaandortega.com
`Email: rrodriguez@dortaandortega.com
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`Attorneys for Appellant.
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 6 of 7
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`CERTIFICATE OF COMPLIANCE
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`Pursuant to Fed. R. App. P. 32(g), I certify the foregoing document complies
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`with the type-volume limitations of Fed. R. App. P. 27(d)(2)(A) because it contains
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`239 words, as created by Microsoft Word, excluding the items that may be excluded
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`under Fed. R. App. P. 32(f).
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`Dated: February 16, 2024
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`/s/ Omar Ortega
`Omar Ortega, Esq.
`Attorney for Appellant
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`USCA11 Case: 23-13156 Document: 40 Date Filed: 02/16/2024 Page: 7 of 7
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`CERTIFICATE OF SERVICE
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` certify that on February 16, 2024, I electronically filed the foregoing with
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`the United States Court of Appeals for the Eleventh Circuit by using the CM/ECF
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`system which will send a notice of electronic filing to appellees’ counsel of record
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`who are registered CM/ECF users.
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`/s/ Omar Ortega
`Omar Ortega, Esq.
`Attorney for Appellant
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`4
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