Motion,Ex Parte: MODE TRANSPORTATION, LLC vs STAPLETON-SPENCE PACKING CO.

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                                Filing # 165993266 E-Filed 02/02/2023 11:54:34 AM


                                                               IN THE COUNTY COURT, FOURTH
                                                               JUDICIAL CIRCUIT, IN AND FOR
                                                               DUVAL COUNTY, FLORIDA

                                                               CASE NO.: 16-2022-CC-015554
                                                               DIVISION: CC-F

           MODE TRANSPORTATION, LLC,
           a Delaware Limited Liability Company,

                                 Plaintiff,

           v.

           STAPLETON-SPENCE PACKING CO.,
           a California Corporation,

                             Defendant.
           _____________________________________/

                MOTION FOR EXTENSION OF TIME TO EFFECT SERVICE OF PROCESS

                  Plaintiff, MODE TRANSPORTATION, LLC., (hereinafter “MODE”), by and through

           undersigned counsel, files this Motion for Extension of Time to Effect Service of Process on

           Defendant, and as grounds thereof would show:

                  1.     The Complaint in this case was filed on November 9, 2022.

                  2.     Plaintiff has made good faith attempts to effect service on Defendant to no avail.

                  3.     Affidavit of Non-Service has been attached hereto as Composite Exhibit “A” and

           will be filed contemporaneously with this Motion.

                  4.     Upon information and belief, service was not properly effected on the California

           Secretary of State, as such Counsel for Plaintiff requests additional time to properly serve the

           Defendant.

                  5.     Plaintiff respectfully requests an additional 90 days in which to effectuate service

           of process on Defendant.

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ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 02/02/2023 05:49:07 PM
Wherefore, the undersigned respectfully requests this Court grant the relief sought herein.

Dated this 2nd day of February, 2023.

                              /s/ Pamela Simmons, Esq
                              Pamela Simmons, Esquire
                              Florida Bar No.: 389269
                              4500 Salisbury Road, Suite 305
                              Jacksonville, Florida 32216
                              Telephone No.: (888) 301-7720
                              Facsimile No.: (904) 212-2316
                              Primary: Pamela.Simmons@modetransportation.com
                              Secondary: Heather.Sudo@modetransportation.com
                              Attorney for Plaintiff, MODE Transportation, LLC




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                                               IN THE COUNTY COURT IN AND FOR DUVAL COUNTY, FLORIDA

Mode Transportation, LLC                                                         Case No.:      16-2022-CC-015554-XXXX-MA
                                                          Plaintiff/Petitioner
vs.
Stapleton-Spence Packing Co.                                                     DECLARATION OF NON-SERVICE OF
                                                      Defendant/Respondent       Summons; Complaint; Civil Cover Sheet


Received by Mike Singh, on the 22nd day of November, 2022 at 4:55 PM to be served upon Stapleton-Spence
Packing Co. c/o Martin Bradley Stapleton as Registered Agent at 1900 California 99, Gridley, Butte County, CA
95948.

On the 1st day of December, 2022 at 9:39 AM, I, Mike Singh, NON-SERVED Stapleton-Spence Packing Co. c/o
Martin Bradley Stapleton as Registered Agent.

NON-SERVICE after due search, careful inquiry and diligent attempts at 1900 California 99, Gridley, Butte County, CA
95948, I have been unable to effect process upon the person/entity being served due to the following reason(s):
11/27/2022 10:53 AM: There was no answer at the address.
12/1/2022 9:39 AM: The property appeared vacant which was supported by empty inside, neighbor and vacancy
notice posted.

Service Fee Total: $129.00

I am a citizen of the United States, over the age of eighteen, not a party to nor interested in the above entitled action, and
have the proper authority in the jurisdiction in which this service was made. Under penalties of perjury, I declare that I
have read the foregoing document and that the facts stated in it are true and accurate.
          {{t:s;r:y;o:"Signer";w:199;h:25;}}




NAME:                                                                      2000-002                        12/01/2022
                                                                                                           {{t:t;r:y;o:"Signer";l:"Date";w:70;h:10;v:"13435fa6c2a17f83177fcbb5c4a9376ce85befeb";}}




          Mike Singh                                                       Server ID #                     Date




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              REF: Stapleton-Spence                                                                                                  Tracking #: 0097293722
                                                              EXHIBIT "A"