Preview
Filing# 164606495 E-Filed 01/12/2023 10:38:09 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
i
DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC'S
UNOPPOSED MOTION TO CONTINUE TRIAL
AND EXTEND PRE-TRIAL DEADLINES
Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned
counsel, pursuant to Fla. R. Civ. P. 1.460, hereby moves this Honorable Court to continue the
trial ofthis matter with all deadlines,and as grounds therefore
pretrial states:
1. This is a negligentsecuritycase that is scheduled for jury trial on the Court's
three-week calendar sometime between May 8,2023, and May 26,2023. The Calendar Call is
scheduled for May 1, 2023.
2. Unfortunately,discoveryin this matter will not be completed before the Calendar
Call. Due to the withdrawal of Plaintiff's former counsel, Plaintiff's depositionwas only recently
completed on December 7,2022. The partiesneed to complete additional non-party discovery
based on Plaintiff's depositiontestimony includingissuingrelevant subpoenas to her medical
providers,employers, and insurers,and taking the depositionsof various witnesses.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/12/2023 10:38:08 AM.****
3. As such, Defendant respectfullyrequests a continuance of the trial and an
extension of all deadlines to give all partiesadditional time to complete discovery and
pre-trial
ready this matter for trial. Defendant requests that the trial be continued by 2-3 months and that
all deadlines be extended accordingly.
pre-trial
4. Good cause exists as the basis for the continuance of jury trial and pre-
deadlines, the request for continuance
trial/discovery is not made to needlessly delay the
resolution of this matter, to increase the expense to any party, or to inconvenience any party, and
the need for a continuance is not the result of lack of diligence in attempting to complete
discoveryand prepare for jury trial in keeping with this Court's Orders.
5. The trial court has broad discretion in grantingor denying a continuance. See
Myers v. Siegel,920 So. 2d 1241, 1242 (Fla.5th DCA 2006) (citingOnett v. Ahola, 780 So. 2d
979 (Fla. 5th DCA 2001)) (holding that while trial courts are endowed with rather broad
discretion in deciding whether to grant or deny a motion for continuance, the exercise of that
discretion is not absolute);
Thompson v. General Motors Corp.,439 So. ld 1012, 1013 (Fla.2d
DCA 1983) (findingthat the trial court has broad discretion in granting or denying a
continuance).
6. This is the first request for a continuance of the trial by any party in this matter,
and Plaintiff has no objectionto the continuance or extension of the pre-trial
deadlines. A
consent signed by a representativeof Defendant, GG RE HOLLYWOOD BEACH 613 LLC, is
attached hereto.
WHEREFORE, Defendant, GG RE HOLLYWOOD BEACH 613 LLC, respectfully
requests that this Court enter an order grantingthe instant Motion and removing this action from
the Court's three-week trial calendar between May 8,2023, and May 26,2023, removing this
2
action from the Calendar Call scheduled for May 1, 2023, continuingthe trial by 2-3 months as
the Court's calendar allows, extendingthe time for the partiesto complete discoveryand comply
deadlines;and any other relief this Court deems justand proper.
with pre-trial
DATED this ,th
12 day o f January, 2023.
ANDERSONGLENN LLP
/s/ .John .J. Glenn
John J. Glenn, Esq.
Florida Bar No.. 957860
Jglenn@asglaw.com
Amanda N. Rumker, Esquire
Florida Bar No.. 125580
arumker@asglaw.com
2650 North MilitaryTrail,Suite 430
Boca Raton, Florida 33431
Tel.: (561) 893-9192
Fax: (561) 893-9194
Attorneysfor Defendant, GG re Hollywood
Beach 613, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY on this 12th day of January, 2023, I electronically
that filed the
foregoingdocument with the Clerk of the Court using Florida Court's E-FilingPortal and certify
that all counsel of record have been served via transmission of Notice of Electronic Filing
generated by Florida Court E-Filing Portal or in some other authorized manner for those counsel
or partieswho are not authorized to receive electronically
Notices of Electronic Filing.
/s/ .John .J. Glenn
John J. Glenn, Esq.
3
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO.: CACE-21-016578
JOY FURER,
Plaintiff,
V
GG RE HOLLYWOOD BEACH 613 LLC,
and RELAXPRO, LLC,
Defendants.
i
DEFENDANT'S AUTHORIZATION FOR CONTINUANCE OF JURY TRIAL
I, VICTOR GOLDENBERG, President of Defendant, GG RE HOLLYWOOD
BEACH 613 LLC, Defendant in the above-entitled and numbered cause of action,hereby certify
that I agree with and have authorized my counsel to file a Motion to Continue the Trial and Pre-
Trial deadlines and to seek a 2-3 month continuance of the jury trial currentlyscheduled in this
matter for between May 8,2023, and May 26,2023.
DATED the th
111 day o f January,2023.
GG RE HOLLYWOOD BEACH 613 LLC
/s/ Victor Goldenberjz
VICTOR GOLDENBERG
President
Preview
Filing# 164606495 E-Filed 01/12/2023 10:38:09 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. i DEFENDANT GG RE HOLLYWOOD BEACH 613 LLC'S UNOPPOSED MOTION TO CONTINUE TRIAL AND EXTEND PRE-TRIAL DEADLINES Defendant, GG RE HOLLYWOOD BEACH 613 LLC, by and through its undersigned counsel, pursuant to Fla. R. Civ. P. 1.460, hereby moves this Honorable Court to continue the trial ofthis matter with all deadlines,and as grounds therefore pretrial states: 1. This is a negligentsecuritycase that is scheduled for jury trial on the Court's three-week calendar sometime between May 8,2023, and May 26,2023. The Calendar Call is scheduled for May 1, 2023. 2. Unfortunately,discoveryin this matter will not be completed before the Calendar Call. Due to the withdrawal of Plaintiff's former counsel, Plaintiff's depositionwas only recently completed on December 7,2022. The partiesneed to complete additional non-party discovery based on Plaintiff's depositiontestimony includingissuingrelevant subpoenas to her medical providers,employers, and insurers,and taking the depositionsof various witnesses. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/12/2023 10:38:08 AM.**** 3. As such, Defendant respectfullyrequests a continuance of the trial and an extension of all deadlines to give all partiesadditional time to complete discovery and pre-trial ready this matter for trial. Defendant requests that the trial be continued by 2-3 months and that all deadlines be extended accordingly. pre-trial 4. Good cause exists as the basis for the continuance of jury trial and pre- deadlines, the request for continuance trial/discovery is not made to needlessly delay the resolution of this matter, to increase the expense to any party, or to inconvenience any party, and the need for a continuance is not the result of lack of diligence in attempting to complete discoveryand prepare for jury trial in keeping with this Court's Orders. 5. The trial court has broad discretion in grantingor denying a continuance. See Myers v. Siegel,920 So. 2d 1241, 1242 (Fla.5th DCA 2006) (citingOnett v. Ahola, 780 So. 2d 979 (Fla. 5th DCA 2001)) (holding that while trial courts are endowed with rather broad discretion in deciding whether to grant or deny a motion for continuance, the exercise of that discretion is not absolute); Thompson v. General Motors Corp.,439 So. ld 1012, 1013 (Fla.2d DCA 1983) (findingthat the trial court has broad discretion in granting or denying a continuance). 6. This is the first request for a continuance of the trial by any party in this matter, and Plaintiff has no objectionto the continuance or extension of the pre-trial deadlines. A consent signed by a representativeof Defendant, GG RE HOLLYWOOD BEACH 613 LLC, is attached hereto. WHEREFORE, Defendant, GG RE HOLLYWOOD BEACH 613 LLC, respectfully requests that this Court enter an order grantingthe instant Motion and removing this action from the Court's three-week trial calendar between May 8,2023, and May 26,2023, removing this 2 action from the Calendar Call scheduled for May 1, 2023, continuingthe trial by 2-3 months as the Court's calendar allows, extendingthe time for the partiesto complete discoveryand comply deadlines;and any other relief this Court deems justand proper. with pre-trial DATED this ,th 12 day o f January, 2023. ANDERSONGLENN LLP /s/ .John .J. Glenn John J. Glenn, Esq. Florida Bar No.. 957860 Jglenn@asglaw.com Amanda N. Rumker, Esquire Florida Bar No.. 125580 arumker@asglaw.com 2650 North MilitaryTrail,Suite 430 Boca Raton, Florida 33431 Tel.: (561) 893-9192 Fax: (561) 893-9194 Attorneysfor Defendant, GG re Hollywood Beach 613, LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY on this 12th day of January, 2023, I electronically that filed the foregoingdocument with the Clerk of the Court using Florida Court's E-FilingPortal and certify that all counsel of record have been served via transmission of Notice of Electronic Filing generated by Florida Court E-Filing Portal or in some other authorized manner for those counsel or partieswho are not authorized to receive electronically Notices of Electronic Filing. /s/ .John .J. Glenn John J. Glenn, Esq. 3 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-016578 JOY FURER, Plaintiff, V GG RE HOLLYWOOD BEACH 613 LLC, and RELAXPRO, LLC, Defendants. i DEFENDANT'S AUTHORIZATION FOR CONTINUANCE OF JURY TRIAL I, VICTOR GOLDENBERG, President of Defendant, GG RE HOLLYWOOD BEACH 613 LLC, Defendant in the above-entitled and numbered cause of action,hereby certify that I agree with and have authorized my counsel to file a Motion to Continue the Trial and Pre- Trial deadlines and to seek a 2-3 month continuance of the jury trial currentlyscheduled in this matter for between May 8,2023, and May 26,2023. DATED the th 111 day o f January,2023. GG RE HOLLYWOOD BEACH 613 LLC /s/ Victor Goldenberjz VICTOR GOLDENBERG President