On May 13, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Grant, Heather,
Vadillo, Francisco Gabriel,
and
Grant, Heather,
Lyft Florida Inc,
Lyft, Inc.,
Vadillo, David,
Vadillo, Franciso Gabriel,
for Auto Negligence
in the District Court of Broward County.
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Filing # 128230698 E-Filed 06/07/2021 02:16:33 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
HEATHER GRANT,
Plaintiff.
VS. CASE NO- CACE 21-009583 (21)
DAVID VADILLO and
LYFT FLORIDA, INC. d/b/a LYFT, INC.,
Defendants.
i
DEFENDANT'S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF'S COMPLAINT
Defendant, LYFT, INC. (improperly identified as Lyft Florida, Inc.), by and through its
undersigned counsel, pursuant to the Florida Rules of Civil Procedure, moves for an extension of
time to respond to Plaintiff's Complaint. In support, Defendant states:
1. Defendant recently retained counsel to defend its interests in this lawsuit.
Defendant and its counsel require additional time to respond to Plaintiff's Complaint.
2. This is Defendant's first request for an extension oftime to respond to the
Complaint.
3 Defendant requested an extension of time from Plaintiff, however as of the filing
of this motion Defendant has not received a response.
4. This request is being filed in good faith and not for the purpose of unnecessary
delay.
WHEREFORE, Defendant, LYFT, INC., respectfully requests that this Court grant
Defendant an extension to respond to Plaintiff's Complaint, and for any additional relief that this
Court finds just and proper.
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/07/2021 02:16:33 PM.****
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the
7th
Clerk of Court and via Florida e-Filing Portal to the following, this 7 day of June, 2021.
Jon A. Zepnick
Ansel & Miller, LLC
1939 Tyler Street
Hollywood, Florida 33020
TEL: 954-922-9100
eansel@anselmiller.com
(Counsel for Plaintiff)
sl Douglas Ede
DOUGLAS EDE
Florida Bar No.: 764787
E-mail: dede@rumberger.corn (primary)
com and
dedesecy@rumberger.com (secondary)
LOREN M. KORKIN
Florida Bar No.. 1010531
E-mail: (primary)
com and
com (secondary)
Rumberger, Kirk &
Caldwell, P.A.
Brickell City Tower, Suite 3000
80 Southwest 8th Street
Miami, Florida 33130-3037
Tel: 305.358.5577
Fax: 305.371.7580
Attorneys for Lyft, Inc.
2
Document Filed Date
June 07, 2021
Case Filing Date
May 13, 2021
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Filing # 128230698 E-Filed 06/07/2021 02:16:33 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HEATHER GRANT, Plaintiff. VS. CASE NO- CACE 21-009583 (21) DAVID VADILLO and LYFT FLORIDA, INC. d/b/a LYFT, INC., Defendants. i DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Defendant, LYFT, INC. (improperly identified as Lyft Florida, Inc.), by and through its undersigned counsel, pursuant to the Florida Rules of Civil Procedure, moves for an extension of time to respond to Plaintiff's Complaint. In support, Defendant states: 1. Defendant recently retained counsel to defend its interests in this lawsuit. Defendant and its counsel require additional time to respond to Plaintiff's Complaint. 2. This is Defendant's first request for an extension oftime to respond to the Complaint. 3 Defendant requested an extension of time from Plaintiff, however as of the filing of this motion Defendant has not received a response. 4. This request is being filed in good faith and not for the purpose of unnecessary delay. WHEREFORE, Defendant, LYFT, INC., respectfully requests that this Court grant Defendant an extension to respond to Plaintiff's Complaint, and for any additional relief that this Court finds just and proper. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/07/2021 02:16:33 PM.**** CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the 7th Clerk of Court and via Florida e-Filing Portal to the following, this 7 day of June, 2021. Jon A. Zepnick Ansel & Miller, LLC 1939 Tyler Street Hollywood, Florida 33020 TEL: 954-922-9100 eansel@anselmiller.com (Counsel for Plaintiff) sl Douglas Ede DOUGLAS EDE Florida Bar No.: 764787 E-mail: dede@rumberger.corn (primary) com and dedesecy@rumberger.com (secondary) LOREN M. KORKIN Florida Bar No.. 1010531 E-mail: (primary) com and com (secondary) Rumberger, Kirk & Caldwell, P.A. Brickell City Tower, Suite 3000 80 Southwest 8th Street Miami, Florida 33130-3037 Tel: 305.358.5577 Fax: 305.371.7580 Attorneys for Lyft, Inc. 2