On August 24, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Strike C, Llc,
Strike X Llc,
and
Gulfstream Park Racing Association Inc,
Stronach, Belinda,
Village At Gulfstream Park, Llc,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 135283839 E-Filed 09/24/2021 03:21:10 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE21016240
STRIKE X LLC,
Plaintiff,
V
VILLAGE AT GULFSTREAM PARK,
LLC,
Defendant.
i
DEFENDANT'S MOTION FOR ENLARGEMENT OF
TIME TO RESPOND TO COMPLAINT
Defendant, Village at Gulfstream Park, LLC ("Defendant"), by and through undersigned
counsel, hereby move pursuant to Florida Rule of Civil Procedure 1.090(b) for an enlargement of
time, through and including October 25, 2021, within which to respond to the Complaint filed by
Plaintiff, Strike X LLC ("Plaintiff'). In support ofthis Motion, Defendant states as follows:
1. Plaintiff filed its Complaint on August 24, 2021, alleging that Defendant breached
a commercial lease for retail and restaurant space.
2. Service purports to have been made on September 15,2021.
3 Assuming service was proper, Defendant's response to the Complaint is due to be
filed on or before October 5,2021.
4. Undersigned counsel sought the consent of the Plaintiff for a fifteen day
enlargement. Rather than extending this often-granted courtesy, Plaintiff sought to impose
conditions on the enlargement that were unreasonable.
5. Undersigned counsel requires additional time to prepare a response to the
Complaint. Specifically,undersigned counsel needs additional time to investigate the allegations
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/24/2021 03:21:10 PM.****
in the Complaint and perform the necessary research. Furthermore, the undersigned is scheduled
for two trials in the next 60 days. Thus, the undersigned requires additional time to prepare an
appropriate response. On reflection, a
twenty day enlargement is necessary.
6. Counsel for the Defendant has conferred with Plaintiff's counsel regarding the
requested enlargement who refused to grant the professional courtesy without placing unreasonable
conditions on its approval.
7. The requested enlargement is made in good faith and not for purposes of delay. The
parties will not be prejudiced by the relief requested.
WHEREFORE, Defendant respectfully requests the Court enter an order extending the
time by which Defendant must respond to the Complaint to and including October 25, 2021, and
granting Defendant such other relief as is just and proper.
Respectfully submitted,
GREENBERG TRAURIG, P.A.
ind
333 S.E. 21 Avenue, Suite 4400
Miami, Florida 33131
Telephone: (305) 579-0519
Facsimile: (305) 579-0717
By: s/Michael N. Kreitzer
Michael N. Kreitzer, Esq.
Florida Bar No. 705561
kreitzerm@gtlaw.com
belloy@gtlaw.com
flservice@gtlaw.com
Jordanna Ishmael, Esq.
Florida Bar No. 1011647
ishmaelj@gtlaw.com
abrahamd@gtlaw.com
Attorneys for Village at Gulfstream Park, LLC
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy o f the foregoing was served by e-mail via
the Florida Court E-Filing Portal, this 24th day of September, 2021, on.
ZARCO EINHORN SALKOWSKI & BRITO, P.A.
One Biscayne Tower
2 South Biscayne Boulevard, 34th Floor
Miami, Florida 33131
Telephone: (305) 374-5418
Facsimile: (305) 374-5428
Robert Zarco
Florida Bar No. 502138
rzarco@zarcolaw.com
Robert F. Salkowski
Florida Bar No. 903124
acoro@zarcolaw.com
Mary Nikezic
Florida Bar No. 92928
Colby Conforti
Florida Bar No. 92928
By: s/Michael N. Kreitzer
3
Document Filed Date
September 24, 2021
Case Filing Date
August 24, 2021
Category
Contract and Indebtedness
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Filing # 135283839 E-Filed 09/24/2021 03:21:10 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION CASE NO. CACE21016240 STRIKE X LLC, Plaintiff, V VILLAGE AT GULFSTREAM PARK, LLC, Defendant. i DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO COMPLAINT Defendant, Village at Gulfstream Park, LLC ("Defendant"), by and through undersigned counsel, hereby move pursuant to Florida Rule of Civil Procedure 1.090(b) for an enlargement of time, through and including October 25, 2021, within which to respond to the Complaint filed by Plaintiff, Strike X LLC ("Plaintiff'). In support ofthis Motion, Defendant states as follows: 1. Plaintiff filed its Complaint on August 24, 2021, alleging that Defendant breached a commercial lease for retail and restaurant space. 2. Service purports to have been made on September 15,2021. 3 Assuming service was proper, Defendant's response to the Complaint is due to be filed on or before October 5,2021. 4. Undersigned counsel sought the consent of the Plaintiff for a fifteen day enlargement. Rather than extending this often-granted courtesy, Plaintiff sought to impose conditions on the enlargement that were unreasonable. 5. Undersigned counsel requires additional time to prepare a response to the Complaint. Specifically,undersigned counsel needs additional time to investigate the allegations *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/24/2021 03:21:10 PM.**** in the Complaint and perform the necessary research. Furthermore, the undersigned is scheduled for two trials in the next 60 days. Thus, the undersigned requires additional time to prepare an appropriate response. On reflection, a twenty day enlargement is necessary. 6. Counsel for the Defendant has conferred with Plaintiff's counsel regarding the requested enlargement who refused to grant the professional courtesy without placing unreasonable conditions on its approval. 7. The requested enlargement is made in good faith and not for purposes of delay. The parties will not be prejudiced by the relief requested. WHEREFORE, Defendant respectfully requests the Court enter an order extending the time by which Defendant must respond to the Complaint to and including October 25, 2021, and granting Defendant such other relief as is just and proper. Respectfully submitted, GREENBERG TRAURIG, P.A. ind 333 S.E. 21 Avenue, Suite 4400 Miami, Florida 33131 Telephone: (305) 579-0519 Facsimile: (305) 579-0717 By: s/Michael N. Kreitzer Michael N. Kreitzer, Esq. Florida Bar No. 705561 kreitzerm@gtlaw.com belloy@gtlaw.com flservice@gtlaw.com Jordanna Ishmael, Esq. Florida Bar No. 1011647 ishmaelj@gtlaw.com abrahamd@gtlaw.com Attorneys for Village at Gulfstream Park, LLC 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy o f the foregoing was served by e-mail via the Florida Court E-Filing Portal, this 24th day of September, 2021, on. ZARCO EINHORN SALKOWSKI & BRITO, P.A. One Biscayne Tower 2 South Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (305) 374-5418 Facsimile: (305) 374-5428 Robert Zarco Florida Bar No. 502138 rzarco@zarcolaw.com Robert F. Salkowski Florida Bar No. 903124 acoro@zarcolaw.com Mary Nikezic Florida Bar No. 92928 Colby Conforti Florida Bar No. 92928 By: s/Michael N. Kreitzer 3