Document for STAYTON, ROBERT JL vs. CELEBRATION COMMUNITY DEVELOPMENT DISTRICT

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                                Filing # 154998508 E-Filed 08/09/2022 05:28:20 PM


                                                                      IN THE CIRCUIT COURT OF THE
                                                                      NINTH JUDICIAL CIRCUIT, IN
                                                                      AND FOR OSCEOLA COUNTY,
                                                                      FLORIDA

         ROBERT J.L. STAYTON,                                         CASE NO.: 2021-CA-2435

                 Plaintiff,

         v.

         CELEBRATION COMMUNITY
         DEVELOPMENT DISTRICT,

               Defendant.
         ______________________________/

                              DEFENDANT’S MOTION TO EXTEND TIME TO RESPOND TO
                                          SUPPLEMENTAL DISCOVERY

               COMES NOW the Defendant, CELEBRATION COMMUNITY DEVELOPMENT

        DISTRICT (hereafter “CCDD”), by and through its undersigned counsel, and pursuant to Florida

        Rules of Civil Procedure and hereby files its Motion for Extension of Time to file its Response to

        Supplemental Discovery filed by Plaintiff, ROBERT J.L. STAYTON, (hereinafter referred to as

        the “Plaintiff”), and in support thereof states as follows:

               1.       Plaintiff filed a Supplemental Request to Produce on or about July 12, 2022.

               2.       Pursuant to Florida Rules of Civil Procedure 1.340 and 1.350, CCDD has 30 days

        upon which to file a response to this pleading, which falls on August 11, 2022.

               3.       CCDD is in need of additional time to serve its responses to the Plaintiff’s

        Supplemental Request to Produce.

               4.       This Motion is not dilatory in nature and there will be no prejudice to the Plaintiff

        in the granting of this Motion.

               5.       Florida Rule of Civil Procedure 1.090(b) states in pertinent part:
              (b) Enlargement. When an act is required or allowed to be done at or within
              a specified time by order of court, by these rules, or by notice given
              thereunder, for cause shown the court at any time in its discretion (1) with
              or without notice, may order the period enlarged if request therefore is made
              before the expiration of the period originally prescribed or as extended by a
              previous order . . .

       6.     Accordingly, CCDD requests that this Court enlarge or otherwise toll its

requirement to respond to Plaintiff’s Supplemental Discovery as mentioned above.

       7.     Where, as here, a party has shown good cause and requests an enlargement of time

within the deadline otherwise prescribed by Florida Rules of Civil Procedure, this Court should

grant the motion and provide an extension. F.R.C.P. Rule 1.090(b)(1).

       WHEREFORE, the Defendant, CELEBRATION COMMUNITY DEVELOPMENT

DISTRICT, respectfully requests this Court enter an Order granting it additional time to respond

to Plaintiff’s Supplemental Discovery and any other relief this Court deems appropriate and just

under the circumstances.

                               CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that on this 9th day of August, 2022 a true and correct copy of the

foregoing has been furnished via E-Service, compliant with Rule of Judicial Administration 2.516,

to: Travis J. McMillen, Esquire, Bogin Munns & Munns, P.A., 1000 Legion Place, Suite #1000,

Orlando, Florida 32801, mramos-toja@boginmunns.com; bmmservice@boginmunns.com.




                      {Remainder of page intentionally left blank}
KELLEY KRONENBERG
Attorneys for Defendant
20 North Orange Avenue, Suite 1207
Orlando, Florida 32801
Phone:         (407) 648-9450
Fax:           (407) 648-4167
Primary: dgordon@kelleykronenberg.com
Secondary: dshpleadings@kelleykronenberg.com
Tertiary: kphilipson@kelleykronenberg.com

  By:   /s/ David M. Gordon
        DAVID M. GORDON, ESQ.
        Florida Bar No.: 115723