On December 31, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Mangano, Anne,
Mangano, Joseph,
and
Garden Fresh Restaurant Corp Dba Sweet Tomatoes,
for Negligence - Premises Liability Commercial
in the District Court of Collier County.
Preview
Filing # 27641240 E-Filed 05/22/2015 03:02:23 PM
IN THE CIRCUIT COURT OF THE 20th
JUDICIAL CIRCUIT IN AND FOR
COLLIER COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO, 11-2014-CA-002827-0001-XX
ANNE MANGANDO and JOSEPH
MANGANO, her husband,
Plaintiffs,
v.
GARDEN FRESH RESTAURANT CORP.
d/b/a SWEET TOMATOES,
Defendant.
DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO
DISCOVERY SERVED WITH THE COMPLAINT
COMES NOW, Defendant, GARDEN FRESH RESTAURANT CORP. d/b/a SWEET
TOMATOES (“Garden Fresh” and/or “Defendant”), by and through undersigned counsel and in
accordance with the applicable Florida Rules of Civil Procedure, hereby moves for an extension of
time to respond to the discovery served with the Complaint, including request for production and
interrogatories, and states:
1. Plaintiff served discovery with the filing of the Complaint, including request for
production and interrogatories. This matter was then removed to the United States District Court for
the Middle District of Florida.
2. On or about May 11, 2015, an Order was entered remanding this matter back to this
Court. Undersigned counsel does not have the complete file and requires additional time to
investigate the allegations in Plaintiffs Complaint and to confer with the client.
Filed with Collier County Clerk of Courts3. Due to a number of pressing commitments in various litigation matters and an
upcoming trial, including that this case was just recently remanded to this Court, counsel for
Defendant has been unable to meet and confer with the client or investigate the allegations raised in
the Complaint.
4. Accordingly, Defendant respectfully requests a brief extension of time to respond to
the discovery requests.
5. Undersigned counsel will contact Plaintiff's counsel in an effort to obtain counsel's
agreement to an extension of time. However, no agreement on this issue has yet been reached.
6. This request is not sought to injure, prejudice or delay this cause.
WHEREFORE, for the foregoing reasons, Defendant respectfully requests that the
Court enter an Order granting Defendant a reasonable extension of time to respond to Plaintiff's
discovery requests and for such further and other relief as the Court deems just and proper.
THEREBY CERTIFY that a true and correct copy of the foregoing was sent via email this
22" day of May, 2015 to Adam Trop, Esq., Trop Law Group, P.A., 3860 West Commercial Blvd.,
Fort Lauderdale, FL 33309, adamtrop@aol.com and cindy@troplawgroup.com.
Respectfully submitted,
/s/ Michael Alexander Garcia
Michael Alexander Garcia
Fla. Bar No. 0161055
Email: mgarcia@fowler-white.com
FOWLER WHITE BURNETT, P.A.
Espirito Santo Plaza, Fourteenth Floor
1395 Brickell Avenue
Miami, Florida 33131
Telephone: (305) 789-9200
Facsimile: (305) 789-9201
Attorney for Defendant
GARDEN FRESH RESTAURANT CORP.
4825-0325-3796, v. 1
Case Filing Date
December 31, 2014
Category
Negligence - Premises Liability Commercial
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Filing # 27641240 E-Filed 05/22/2015 03:02:23 PM IN THE CIRCUIT COURT OF THE 20th JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO, 11-2014-CA-002827-0001-XX ANNE MANGANDO and JOSEPH MANGANO, her husband, Plaintiffs, v. GARDEN FRESH RESTAURANT CORP. d/b/a SWEET TOMATOES, Defendant. DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY SERVED WITH THE COMPLAINT COMES NOW, Defendant, GARDEN FRESH RESTAURANT CORP. d/b/a SWEET TOMATOES (“Garden Fresh” and/or “Defendant”), by and through undersigned counsel and in accordance with the applicable Florida Rules of Civil Procedure, hereby moves for an extension of time to respond to the discovery served with the Complaint, including request for production and interrogatories, and states: 1. Plaintiff served discovery with the filing of the Complaint, including request for production and interrogatories. This matter was then removed to the United States District Court for the Middle District of Florida. 2. On or about May 11, 2015, an Order was entered remanding this matter back to this Court. Undersigned counsel does not have the complete file and requires additional time to investigate the allegations in Plaintiffs Complaint and to confer with the client. Filed with Collier County Clerk of Courts3. Due to a number of pressing commitments in various litigation matters and an upcoming trial, including that this case was just recently remanded to this Court, counsel for Defendant has been unable to meet and confer with the client or investigate the allegations raised in the Complaint. 4. Accordingly, Defendant respectfully requests a brief extension of time to respond to the discovery requests. 5. Undersigned counsel will contact Plaintiff's counsel in an effort to obtain counsel's agreement to an extension of time. However, no agreement on this issue has yet been reached. 6. This request is not sought to injure, prejudice or delay this cause. WHEREFORE, for the foregoing reasons, Defendant respectfully requests that the Court enter an Order granting Defendant a reasonable extension of time to respond to Plaintiff's discovery requests and for such further and other relief as the Court deems just and proper. THEREBY CERTIFY that a true and correct copy of the foregoing was sent via email this 22" day of May, 2015 to Adam Trop, Esq., Trop Law Group, P.A., 3860 West Commercial Blvd., Fort Lauderdale, FL 33309, adamtrop@aol.com and cindy@troplawgroup.com. Respectfully submitted, /s/ Michael Alexander Garcia Michael Alexander Garcia Fla. Bar No. 0161055 Email: mgarcia@fowler-white.com FOWLER WHITE BURNETT, P.A. Espirito Santo Plaza, Fourteenth Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorney for Defendant GARDEN FRESH RESTAURANT CORP. 4825-0325-3796, v. 1