On October 22, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Fine Line Electric Inc,
Pmg Driftwood Llc,
Sage Beach Condominium Association, Inc.,
and
Advanced Alarm Service, Inc,
Armstrong Air Condition & Heating Of Central Florida Inc,
Associated Steel And Aluminium Inc,
B Cody Plumbing Inc,
Bradford Products Llc,
Building Envelope Systems Inc,
Calvin Giordano & Associates Inc,
Chm Structrual Engineers Llc,
Construction Specialties Inc,
Dun-Rite Marble & Granite Inc,
East Coast Contractors Supply Inc,
Ferguson Enterprises Inc,
Fine Line Electric Inc,
Flood Panel Llc,
Glenewinkel Construction Company Llc,
Hollywood Stone Inc,
J.L.K Caulking And Coatings Company,
Lushlife Llc,
New Door Installation Co.,
Next Door Installation Co,
Pmg Driftwood Llc,
R&L Painting Inc,
Rosen Materials Llc,
Sage Beach Condominium Association,
Security Innovative Solutions Inc,
Shamrock Engineering Corp,
South Dade Lighting Inc,
South Dade Lighting, Inc.,
Southern Coast Enterprises Inc,
Southern Fire Control Inc,
Tekton Construction Corp,
Urvanx Inc,
Zarrella Construction Inc,
for Neg - Construction Defect
in the District Court of Broward County.
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Filing# 148340062 E-Filed 04/25/2022 04:23:53 PM
IN THE CIRCUIT COURT OF THE
,th
17'
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE-20-017530
CONSOLIDATED WITH
CASE NO. CACE-20-017790
SAGE BEACH CONDOMINIUM
ASSOCIATION, INC. a Florida
not-for-profit
corporation,
Plaintiff.
VS.
PMG DRIFTWOOD LLC,
a Florida limited liability
company, et al.,
Defendants.
i
PMG DRIFTWOOD, LLC,
a Florida limited liability
company,
Cross-Plaintiff.
V
SAGE BEACH CONDOMINIUM
ASSOCIATION, INC., a Florida
not-for-profit
corporation,
Cross-Defendant.
i
SHAMROCK ENGINEERING CORP.'S MOTION FOR EXTENSION OF TIME
Cross-Defendant, SHAMROCK ENGINEERING CORP. ("Shamrock"), moves for an
Order grantingan extension of time within which to respond to the Cross-Claim filed by PMG
DRIFTWOOD, LLC ("PMG"), includingan Order allowing an extension of time to assert any
challengeto jurisdiction,
process, or service of process, and in support thereof would show the
Court as follows:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/25/2022 04:23:53 PM.****
1.
PMG filed its Cross-Claim on April4,2022. As such, Shamrock's response is
due on or before April25,2022.
2.
Due to the press of litigation
and related professionalobligations,
as well as prior
commitments of Shamrock, undersigned counsel has not had sufficient time to evaluate the
claims presented and prepare a proper response to the Cross-Claim of the PMG, includingany
pleadingattackingjurisdiction
over the Shamrock.
3.
Accordingly, Shamrock respectfully
requests no less than thirty(30) additional
days to review the materials necessary to evaluate the Cross-Claim and to file appropriate
motions, objectionsand/or responses thereto.
4.
This motion is without waiver to any and all affirmative defenses that are or may
be applicable.
5.
This motion is made in good faith and not for the purpose of delay
WHEREFORE, Defendant, SHAMROCK ENGINEERING CORP. moves the Court for
entry of an Order extendingthe time within which to serve a response to the Cross-Claim filed
by PMG DRIFTWOOD, LLC by no less than thirty(30)days.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoinghas been furnished by
Electronic Mail Via the Florida Courts E-FilingPortal to all partiesofrecord, includingElijahC.
Waring, Jr.,Esq., Ball Janik, LLP, Counsel for Plaintiff,
100 SE Second Street,Miami Tower,
Suite 3310, Miami, Florida 33131 (ewaring@balljanick.com)and Gary F. Baumann, Esq.,
Baumann Gant & Keeley, P.A., Counsel for PMG Driftwood, 1401 East Broward Blvd., Suite
200, Fort Lauderdale, Florida 33301 (gbaumann@baumannlegal.com), this April25,2022.
SHAPIRO BLASI WASSERMAN & HERMANN PA
Attorneysfor Shamrock Engineering Corp.
CorporateCentre at Boca Raton
7777 Glades Road, Suite 400
Boca Raton, Florida 33434
T: (561)477-7800 Il F: (561)477-7722
sweinstein@sbwh.law
lwood@sbwh.law
By:
/s/ Stuart A. Weinstein
Stuart A. Weinstein, Esq.
Florida Bar No. 0526630
Preview
Filing# 148340062 E-Filed 04/25/2022 04:23:53 PM IN THE CIRCUIT COURT OF THE ,th 17' JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-20-017530 CONSOLIDATED WITH CASE NO. CACE-20-017790 SAGE BEACH CONDOMINIUM ASSOCIATION, INC. a Florida not-for-profit corporation, Plaintiff. VS. PMG DRIFTWOOD LLC, a Florida limited liability company, et al., Defendants. i PMG DRIFTWOOD, LLC, a Florida limited liability company, Cross-Plaintiff. V SAGE BEACH CONDOMINIUM ASSOCIATION, INC., a Florida not-for-profit corporation, Cross-Defendant. i SHAMROCK ENGINEERING CORP.'S MOTION FOR EXTENSION OF TIME Cross-Defendant, SHAMROCK ENGINEERING CORP. ("Shamrock"), moves for an Order grantingan extension of time within which to respond to the Cross-Claim filed by PMG DRIFTWOOD, LLC ("PMG"), includingan Order allowing an extension of time to assert any challengeto jurisdiction, process, or service of process, and in support thereof would show the Court as follows: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/25/2022 04:23:53 PM.**** 1. PMG filed its Cross-Claim on April4,2022. As such, Shamrock's response is due on or before April25,2022. 2. Due to the press of litigation and related professionalobligations, as well as prior commitments of Shamrock, undersigned counsel has not had sufficient time to evaluate the claims presented and prepare a proper response to the Cross-Claim of the PMG, includingany pleadingattackingjurisdiction over the Shamrock. 3. Accordingly, Shamrock respectfully requests no less than thirty(30) additional days to review the materials necessary to evaluate the Cross-Claim and to file appropriate motions, objectionsand/or responses thereto. 4. This motion is without waiver to any and all affirmative defenses that are or may be applicable. 5. This motion is made in good faith and not for the purpose of delay WHEREFORE, Defendant, SHAMROCK ENGINEERING CORP. moves the Court for entry of an Order extendingthe time within which to serve a response to the Cross-Claim filed by PMG DRIFTWOOD, LLC by no less than thirty(30)days. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoinghas been furnished by Electronic Mail Via the Florida Courts E-FilingPortal to all partiesofrecord, includingElijahC. Waring, Jr.,Esq., Ball Janik, LLP, Counsel for Plaintiff, 100 SE Second Street,Miami Tower, Suite 3310, Miami, Florida 33131 (ewaring@balljanick.com)and Gary F. Baumann, Esq., Baumann Gant & Keeley, P.A., Counsel for PMG Driftwood, 1401 East Broward Blvd., Suite 200, Fort Lauderdale, Florida 33301 (gbaumann@baumannlegal.com), this April25,2022. SHAPIRO BLASI WASSERMAN & HERMANN PA Attorneysfor Shamrock Engineering Corp. CorporateCentre at Boca Raton 7777 Glades Road, Suite 400 Boca Raton, Florida 33434 T: (561)477-7800 Il F: (561)477-7722 sweinstein@sbwh.law lwood@sbwh.law By: /s/ Stuart A. Weinstein Stuart A. Weinstein, Esq. Florida Bar No. 0526630