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Guma Aguiar - Motion to Stay

Guma Aguiar - Motion to Stay

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Published by Stefan Kamph

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Published by: Stefan Kamph on Jun 27, 2012
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06/27/2012

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDACASE NO. 09-60136-CIV-SEITZ/SIMONTON
 LEOR EXPLORATION &PRODUCTION LLC, PARDUSPETROLEUM LLC and WILLIAMNATBONY, as Trustee of theDAFNA KAPLAN 2003 EIGHT-YEARGRANTOR RETAINED ANNUITYTRUST and THOMAS KAPLAN 2004TEN-YEAR GRANTOR RETAINEDANNUITY TRUST,Plaintiffs,vs.GUMA AGUIAR,
 
Defendant.___________________________________/ 
MOTION TO STAY PROCEEDINGSAND REQUEST FOR STATUS CONFERENCE
Coffey Burlington hereby moves for a stay of proceedings and requests that a statusconference be scheduled given the tragic disappearance of Guma Aguiar. Press reports indicateGuma Aguiar was last seen on June 19, 2012 and has been reported missing to local authorities.According to press reports, the United States Coast Guard and local police authorities have beensearching for Mr. Aguiar since his watercraft came ashore in the vicinity of Fort Lauderdale,Florida. Given these circumstances, and the possibilities that they present, it is evident thatcounsel for Mr. Aguiar cannot act without appointment by a guardian or conservator as providedby law.
Case 0:09-cv-60136-PAS Document 635 Entered on FLSD Docket 06/22/2012 Page 1 of 4
 
Ellen Aguiar, Mr. Aguiar’s mother, has filed an Emergency Petition for Appointment of Conservator, or, in the alternative, for Emergency Temporary Guardian (“Emergency Petition”),a copy of which is attached hereto. As stated in the Petition:The Absentee's boat washed ashore and was located by the FortLauderdale Police Department on Fort Lauderdale Beach near EastLas Olas Boulevard at approximately 1:15 p.m. on June 20, 2012.The Absentee was not on the boat and has not yet been located buthis cellular phone and wallet were found on the boat by the FortLauderdale Police Department. The boat's engine was still runningand the navigation lights were on at the time the boat went ashore.The Absentee's relatives have not communicated with or beencontacted by the Absentee since June 19, 2012.(Emergency Petition at 2.) The Emergency Petition cites this litigation and seeks the authority torequest “appropriate continuances and extensions of time.” Emergency Petition at 5.For these reasons, Coffey Burlington hereby moves for a stay of proceedings pendingconfirmation of whether Mr. Aguiar is deceased and to extend all pending deadlines in thismatter. We further request a status conference with the Court regarding the requested stay of proceedings before this Court.Coffey Burlington has conferred with counsel for the Plaintiffs, who advised that they areassessing their position regarding this motion at this time.Respectfully submitted,Alan M. Dershowitz, Esq.26 Reservoir StreetCambridge, MA 02138617-661-1965Email:dersh@law.harvard.edu 
Pro Hac Vice Counsel for Defendant Guma Aguiar 
 By: s/David J. Zack______________Kendall Coffey – FBN 259861David J. Zack – FBN 641685Erika S. Handelson, FBN 91133Kimberly J. Freedman, FBN 71826Coffey Burlington, P.L.2699 S Bayshore Drive, PenthouseMiami, FL 33133Tel: 305-858-2900/Fax: 305-858-5261Email:dzack@coffeyburlington.com 
ehandelson@coffeyburlington.comkfreedman@coffeyburlington.com
Counsel for Defendant Guma Aguiar 
 
Case 0:09-cv-60136-PAS Document 635 Entered on FLSD Docket 06/22/2012 Page 2 of 4
 
 
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on June 22, 2012, I electronically filed the foregoingdocument with the Clerk of the Court using CM/ECF. I also certify that a true and correct copyof the foregoing is being served this day on all counsel or parties on the Service List below.By: s/David J. Zack 
Case 0:09-cv-60136-PAS Document 635 Entered on FLSD Docket 06/22/2012 Page 3 of 4

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