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Filing # 121948966 E-Filed 02/23/2021 09:52:43 PM
IN THE CIRCUIT COURT OF THE
SECOND JUDICIAL CIRCUIT, IN AND
FOR GADSDEN COUNTY, FLORIDA
REGINA DAVIS, CASE NO.: 21000024CAA
Plaintiff,
Vv.
GADSDEN SENIOR SERVICES, INC.,
Defendant.
/
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
COME NOW Defendant, GADSDEN SENIOR SERVICES, INC., by and through
its undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, and hereby
moves to Enlarge the Time to Respond to Plaintiff's Complaint and as grounds therefore
states as follows:
1. Defendant’s response to Plaintiffs Complaint is due today by agreement of
Counsel for Plaintiff; however, the undersigned was recently retained in connection with
this litigation and has not had adequate opportunity to review the claim materials and
confer with Defendant regarding all of the allegations in Plaintiff's Complaint.
2. Under the circumstances, additional time is needed to prepare an
appropriate response to Plaintiff's Complaint. Specifically, Defendant respectfully
requests an enlargement of time up to and including Tuesday, March 2, 2021.
3. This motion is brought in good faith and is not for the purpose of interposing
delay in these proceedings.
COLE, SCOTT & KISSANE P.A.
2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL $2809 - (850) 518-1050 (850) 518-1051 FAXCASE NO.: 21000024CAA
4. Defendant has reached out to Counsel for Plaintiff regarding this request;
however, as of the time of filing this Motion, Counsel for Plaintiff has not consented to the
requested extension. Defendant has filed this Motion due to the time-sensitive nature of
the relief requested, but the undersigned will continue efforts to resolve this dispute in
good faith and will notify the Court if the parties have reached an agreement.
WHEREFORE, Defendant, GADSDEN SENIOR SERVICES, INC., hereby
requests an enlargement of time up to and including Tuesday, March 2, 2021, to prepare
its response to Plaintiff's Complaint.
Respectfully submitted,
COLE, SCOTT & KISSANE P.A.
Counsel for Defendant GADSDEN SENIOR
SERVICES, INC
Primary e-mail: erin.centrone@csklegal.com
Secondary e-mail: ross.vickers@csklegal.com
Alternate e-mail: olga.durbin@csklegal.com
Alternate e-mail: olga.durbin@csklegal.com
By: _s/ Ross D. Vickers
ERIN L. CENTRONE
Florida Bar No.: 100189
ROSS D. VICKERS
Florida Bar No.: 121717
2
COLE, SCOTT & KISSANE P.A.
2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL 82309 - (850) 518-1050 (850) 518-1051 FAXCERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 23rd day of February, 2021, a true and correct
copy of the foregoing was filed with the Clerk of Gadsden County by using the Florida
Courts e-Filing Portal, which will send an automatic e-mail message to the following
parties registered with the e-Filing Portal system: Amy B. Kirkpatrick, Esq., Winegardner
Law Firm, 2852 Remington Green Circle, Suite 102, Tallahassee, FL 32308, (850) 270-
9064/(850) 422-0074 (F), Attorney for Plaintiff, Regina Davis and Jennifer A.
Winegardner, Esq., Winegardner Law Firm,
jwinegardner@winegardnerlaw.com;patty.pizzuto@winegardnerlaw.com, 2852
Remington Green Circle, Suite 102, Tallahassee, FL 32308, (850) 270-9064/(850) 422-
0074 (F), Attorney for Plaintiff, Regina Davis.
By: _s/ Ross D. Vickers
ROSS D. VICKERS
Florida Bar No.: 121717
3
COLE, SCOTT & KISSANE P.A.
2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL 82309 - (850) 518-1050 (850) 518-1051 FAX
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Filing # 121948966 E-Filed 02/23/2021 09:52:43 PM IN THE CIRCUIT COURT OF THE SECOND JUDICIAL CIRCUIT, IN AND FOR GADSDEN COUNTY, FLORIDA REGINA DAVIS, CASE NO.: 21000024CAA Plaintiff, Vv. GADSDEN SENIOR SERVICES, INC., Defendant. / DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COME NOW Defendant, GADSDEN SENIOR SERVICES, INC., by and through its undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, and hereby moves to Enlarge the Time to Respond to Plaintiff's Complaint and as grounds therefore states as follows: 1. Defendant’s response to Plaintiffs Complaint is due today by agreement of Counsel for Plaintiff; however, the undersigned was recently retained in connection with this litigation and has not had adequate opportunity to review the claim materials and confer with Defendant regarding all of the allegations in Plaintiff's Complaint. 2. Under the circumstances, additional time is needed to prepare an appropriate response to Plaintiff's Complaint. Specifically, Defendant respectfully requests an enlargement of time up to and including Tuesday, March 2, 2021. 3. This motion is brought in good faith and is not for the purpose of interposing delay in these proceedings. COLE, SCOTT & KISSANE P.A. 2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL $2809 - (850) 518-1050 (850) 518-1051 FAXCASE NO.: 21000024CAA 4. Defendant has reached out to Counsel for Plaintiff regarding this request; however, as of the time of filing this Motion, Counsel for Plaintiff has not consented to the requested extension. Defendant has filed this Motion due to the time-sensitive nature of the relief requested, but the undersigned will continue efforts to resolve this dispute in good faith and will notify the Court if the parties have reached an agreement. WHEREFORE, Defendant, GADSDEN SENIOR SERVICES, INC., hereby requests an enlargement of time up to and including Tuesday, March 2, 2021, to prepare its response to Plaintiff's Complaint. Respectfully submitted, COLE, SCOTT & KISSANE P.A. Counsel for Defendant GADSDEN SENIOR SERVICES, INC Primary e-mail: erin.centrone@csklegal.com Secondary e-mail: ross.vickers@csklegal.com Alternate e-mail: olga.durbin@csklegal.com Alternate e-mail: olga.durbin@csklegal.com By: _s/ Ross D. Vickers ERIN L. CENTRONE Florida Bar No.: 100189 ROSS D. VICKERS Florida Bar No.: 121717 2 COLE, SCOTT & KISSANE P.A. 2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL 82309 - (850) 518-1050 (850) 518-1051 FAXCERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 23rd day of February, 2021, a true and correct copy of the foregoing was filed with the Clerk of Gadsden County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Amy B. Kirkpatrick, Esq., Winegardner Law Firm, 2852 Remington Green Circle, Suite 102, Tallahassee, FL 32308, (850) 270- 9064/(850) 422-0074 (F), Attorney for Plaintiff, Regina Davis and Jennifer A. Winegardner, Esq., Winegardner Law Firm, jwinegardner@winegardnerlaw.com;patty.pizzuto@winegardnerlaw.com, 2852 Remington Green Circle, Suite 102, Tallahassee, FL 32308, (850) 270-9064/(850) 422- 0074 (F), Attorney for Plaintiff, Regina Davis. By: _s/ Ross D. Vickers ROSS D. VICKERS Florida Bar No.: 121717 3 COLE, SCOTT & KISSANE P.A. 2873 REMINGTON GREEN CIRCLE, TALLAHASEE, FL 82309 - (850) 518-1050 (850) 518-1051 FAX