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Filing # 169488544 E-Filed 03/23/2023 02:14:19 PM
IN THE CIRCUIT COURT OF THE EIGHTEENTH
JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA
STEVEN WADE,
Plaintiff,
Vv. Case No. 05-2023-CA-017232
KRISTIN DANAE BLACK a/k/a KRISTIN
BRIMMER; CHARLES DAVID BLACK, a/k/a
CHAD. BLACK, CHAD W. COOPER;
JENNIFER C. COOPER; KEITH PECOT; &
PURSUIT INVESTMENTS, LLC,
Defendants.
MOTION FOR ENLARGEMENT OF TIME
Defendants, Chad William Cooper and Jennifer C. Cooper (collectively, the “Coopers”,
by and through undersigned counsel, and pursuant to Rule 1.090, Florida Rules of Civil
Procedure, hereby move for an extension of time to respond to Plaintiff's Complaint, and in
support hereof would state as follows:
1 On or about February 27, 2023, Plaintiff filed a forty-four (44) page Complaint
naming six (6) party defendants, asserting eleven (11) pleaded counts and containing in total well
over three hundred pleaded allegations.
2. The pleaded allegations against the Coopers, church pastors at Elevation Church’s
Melbourne campus, include claims of aiding and abetting fraud, civil conspiracy, and civil
claims under Florida’s Racketeer Influenced and Corrupt Organization Act (RICO).
3 In addition to the instant case, counsel for Plaintiff, Blake Stewart, is presently
pursing two other civil actions against the Coopers that stem from the same common nucleus of
operative fact alleged in the Complaint sub judice; namely, alleged fraud perpetrated by
Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
Defendant, Charles Black and his now bankrupt company, non-party Legacy Pools, LLC
(“Legacy Pools”).
4 On March 4, 2023, the Coopers were served with a copy of the Complaints and
Summonses in all three pending actions, including the instant case.
5 On Monday, March 20, 2023, the undersigned attorney was retained by the
Coopers to defend all three pending disputes filed against them.
6. On Wednesday, March 23, 2023, the undersigned attorney telephoned Mr.
Stewart requesting a conference call to discuss a reasonable extension of time to respond to the
three complaints. Later that day, Mr. Stewart’s paralegal responded that Mr. Stewart was
unavailable, but would agree to a ten (10) day extension to respond to the three complaints.
7 The undersigned responded by again requesting a conferral call with Mr. Stewart
to discuss a “reasonable extension”, given the circumstances and breadth of the pleaded
allegations contained in the three complaints. To date, Mr. Stewart has not responded to the
undersigned requests for a call to discuss a more reasonable extension.
8 Counsel for the Coopers requires additional time to evaluate this case, to get up to
speed on the entire file and background of these disputes, to evaluate the legal propriety of
Plaintiff’s pleaded allegations and counts, to confer with the Coopers regarding the veracity of
certain allegations, to evaluate possible consolidation of the three pending disputes for discovery
or otherwise, to evaluate the striking of numerous immaterial, impertinent and scandalous details
and exhibits contained in the Complaint, and to prepare a formal response to the Complaint.
9 The requested extension is sought in good faith and not for the purpose of delay.
The requested extension will not prejudice any party to this action because the civil action was
just commenced, no discovery has been completed, there is no case management plan or order in
Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
place, nor any trial date set.
WHEREFORE, Chad William Cooper and Jennifer C. Cooper, hereby move this Court
for a twenty (20) day extension to respond to Plaintiff Complaint through and including April 13,
2023, and for such other and further relief as this Court deems just and proper.
/s/ Joseph C. Crawford
JOSEPH C. CRAWFORD
FL Bar No.: 124653
DEAN MEAD
7380 Murrell Road, Suite 200
Viera, FL 32940
Tel: (321) 259-8900; Fax: (321) 254-4479
E-Mail: jcrawford@deanmead.com
imetress@deanmead.con
Attorney for Defendants, Chad W. Cooper
and Jennifer C. Cooper
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 23rd day of March, 2023, this document was
electronically transmitted to the Clerk of Court via the Florida Courts E-Filing Portal (“FCEP”)
which will send electronic notification to the following counsel of record:
Blake Stewart, Esq.
Stewart Law CS, LLC
1033 Florida Avenue South
Rockledge, Florida 32955
blake@stewartlawes.com
staff@stewartlawes.con
Attorneys for Plaintiff
Us/ Joseph C. Crawford
JOSEPH C. CRAWFORD
Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX
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Filing # 169488544 E-Filed 03/23/2023 02:14:19 PM IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT IN AND FOR BREVARD COUNTY, FLORIDA STEVEN WADE, Plaintiff, Vv. Case No. 05-2023-CA-017232 KRISTIN DANAE BLACK a/k/a KRISTIN BRIMMER; CHARLES DAVID BLACK, a/k/a CHAD. BLACK, CHAD W. COOPER; JENNIFER C. COOPER; KEITH PECOT; & PURSUIT INVESTMENTS, LLC, Defendants. MOTION FOR ENLARGEMENT OF TIME Defendants, Chad William Cooper and Jennifer C. Cooper (collectively, the “Coopers”, by and through undersigned counsel, and pursuant to Rule 1.090, Florida Rules of Civil Procedure, hereby move for an extension of time to respond to Plaintiff's Complaint, and in support hereof would state as follows: 1 On or about February 27, 2023, Plaintiff filed a forty-four (44) page Complaint naming six (6) party defendants, asserting eleven (11) pleaded counts and containing in total well over three hundred pleaded allegations. 2. The pleaded allegations against the Coopers, church pastors at Elevation Church’s Melbourne campus, include claims of aiding and abetting fraud, civil conspiracy, and civil claims under Florida’s Racketeer Influenced and Corrupt Organization Act (RICO). 3 In addition to the instant case, counsel for Plaintiff, Blake Stewart, is presently pursing two other civil actions against the Coopers that stem from the same common nucleus of operative fact alleged in the Complaint sub judice; namely, alleged fraud perpetrated by Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX Defendant, Charles Black and his now bankrupt company, non-party Legacy Pools, LLC (“Legacy Pools”). 4 On March 4, 2023, the Coopers were served with a copy of the Complaints and Summonses in all three pending actions, including the instant case. 5 On Monday, March 20, 2023, the undersigned attorney was retained by the Coopers to defend all three pending disputes filed against them. 6. On Wednesday, March 23, 2023, the undersigned attorney telephoned Mr. Stewart requesting a conference call to discuss a reasonable extension of time to respond to the three complaints. Later that day, Mr. Stewart’s paralegal responded that Mr. Stewart was unavailable, but would agree to a ten (10) day extension to respond to the three complaints. 7 The undersigned responded by again requesting a conferral call with Mr. Stewart to discuss a “reasonable extension”, given the circumstances and breadth of the pleaded allegations contained in the three complaints. To date, Mr. Stewart has not responded to the undersigned requests for a call to discuss a more reasonable extension. 8 Counsel for the Coopers requires additional time to evaluate this case, to get up to speed on the entire file and background of these disputes, to evaluate the legal propriety of Plaintiff’s pleaded allegations and counts, to confer with the Coopers regarding the veracity of certain allegations, to evaluate possible consolidation of the three pending disputes for discovery or otherwise, to evaluate the striking of numerous immaterial, impertinent and scandalous details and exhibits contained in the Complaint, and to prepare a formal response to the Complaint. 9 The requested extension is sought in good faith and not for the purpose of delay. The requested extension will not prejudice any party to this action because the civil action was just commenced, no discovery has been completed, there is no case management plan or order in Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX place, nor any trial date set. WHEREFORE, Chad William Cooper and Jennifer C. Cooper, hereby move this Court for a twenty (20) day extension to respond to Plaintiff Complaint through and including April 13, 2023, and for such other and further relief as this Court deems just and proper. /s/ Joseph C. Crawford JOSEPH C. CRAWFORD FL Bar No.: 124653 DEAN MEAD 7380 Murrell Road, Suite 200 Viera, FL 32940 Tel: (321) 259-8900; Fax: (321) 254-4479 E-Mail: jcrawford@deanmead.com imetress@deanmead.con Attorney for Defendants, Chad W. Cooper and Jennifer C. Cooper CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 23rd day of March, 2023, this document was electronically transmitted to the Clerk of Court via the Florida Courts E-Filing Portal (“FCEP”) which will send electronic notification to the following counsel of record: Blake Stewart, Esq. Stewart Law CS, LLC 1033 Florida Avenue South Rockledge, Florida 32955 blake@stewartlawes.com staff@stewartlawes.con Attorneys for Plaintiff Us/ Joseph C. Crawford JOSEPH C. CRAWFORD Filing 169488544 STEVEN WADE VS CHARLES D BLACK 05-2023-CA-017232-XXXX-XX