On August 21, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Gomez, Catherine,
James, Rachel,
Loffredo, Johanna,
and
Rudd, Levi,
Symmetry Healthcare Management Llc.,
for 3
in the District Court of Broward County.
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Filing# 178050650 E-Filed 07/24/2023 11:04:27 AM
INTHE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
Case No.: CACE21-016096
JOHANNA LOFFREDO; CATHERINE
GOMEZ & RACHEL JAMES,
Plaintiffs,
V
SYMMETRY HEALTHCARE
MANAGEMENT, LLC & LEVI RUDD,
Defendants.
i
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' DISCOVERY
The Defendants, SYMMETRY HEALTHCARE MANAGEMENT, LLC & LEVI
RUDD, file this Motion for Extension of time to Respond to the Plaintiffs' First Set of
First Request
Interrogatories, for Admissions and First Request for Production ("Discovery")
and, in support, states as follows:
1. Plaintiffs served their Discovery upon Defendant.
2. Counsel for the Defendants in this matter has not yet had the opportunity to
review the entire file in order to properlyrespond to Plaintiffs' Discovery. As such, Defendants'
counsel is not in a positionto file a response to the Discovery at this time, and would request an
extension o f time.
3 There is no prejudiceto any party by the grantingof this enlargementof time.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/24/2023 11:04:27 AM.****
Case No.: CACE21-016096
4. This is Defendants' first Motion for Extension of time to respond to the
Discovery, and is made in good faith,in an abundance of caution, and is no intended to delay
action in this matter.
The Defendant, SYMMETRY HEALTHCARE MANAGEMENT, LLC & LEVI RUDD,
request that the Honorable Court enter an Order grantingthis Motion for Extension
respectfully
or grantingany further relief this Court deems justand proper under the circumstances.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the ith
24? day of July,2023, this document was filed using
the Florida Courts E-FilingPortal. This document is being served on all counsel and pro se
partiesof record by the Florida Courts E-Filing Portal,pursuant to and in compliance with Fla.
R. Jud. Admin. 2.516. The mailing and electronic addresses are: Iris Collins-Cruz,Derek Smith
Law Group, PLLC, 701 Brickell Avenue, Suite 1310, Miami, FL 33130, Attorney for Plaintiff,
Johanna Loffredo, Catherine Gomez and Rachel James.
KELLEY KRONENBERG
/W Roxana Gonzalez
Aaron D. Neifeld, Esquire
Fla. Bar No.: 127598
Roxana Gonzalez, Esquire
Fla.Bar No.. 1002990
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone:(954) 370-9970
Facsimile: (954) 382-1988
Attorneys for Defendants
Address for service of pleadingsonly
aneifeld@kelleykronenberg.com
rgonzalez@kelleykronenberg.com
smaler@kelleykronenberg.com
2
Document Filed Date
July 24, 2023
Case Filing Date
August 21, 2021
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Filing# 178050650 E-Filed 07/24/2023 11:04:27 AM INTHE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE21-016096 JOHANNA LOFFREDO; CATHERINE GOMEZ & RACHEL JAMES, Plaintiffs, V SYMMETRY HEALTHCARE MANAGEMENT, LLC & LEVI RUDD, Defendants. i MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' DISCOVERY The Defendants, SYMMETRY HEALTHCARE MANAGEMENT, LLC & LEVI RUDD, file this Motion for Extension of time to Respond to the Plaintiffs' First Set of First Request Interrogatories, for Admissions and First Request for Production ("Discovery") and, in support, states as follows: 1. Plaintiffs served their Discovery upon Defendant. 2. Counsel for the Defendants in this matter has not yet had the opportunity to review the entire file in order to properlyrespond to Plaintiffs' Discovery. As such, Defendants' counsel is not in a positionto file a response to the Discovery at this time, and would request an extension o f time. 3 There is no prejudiceto any party by the grantingof this enlargementof time. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/24/2023 11:04:27 AM.**** Case No.: CACE21-016096 4. This is Defendants' first Motion for Extension of time to respond to the Discovery, and is made in good faith,in an abundance of caution, and is no intended to delay action in this matter. The Defendant, SYMMETRY HEALTHCARE MANAGEMENT, LLC & LEVI RUDD, request that the Honorable Court enter an Order grantingthis Motion for Extension respectfully or grantingany further relief this Court deems justand proper under the circumstances. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the ith 24? day of July,2023, this document was filed using the Florida Courts E-FilingPortal. This document is being served on all counsel and pro se partiesof record by the Florida Courts E-Filing Portal,pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Iris Collins-Cruz,Derek Smith Law Group, PLLC, 701 Brickell Avenue, Suite 1310, Miami, FL 33130, Attorney for Plaintiff, Johanna Loffredo, Catherine Gomez and Rachel James. KELLEY KRONENBERG /W Roxana Gonzalez Aaron D. Neifeld, Esquire Fla. Bar No.: 127598 Roxana Gonzalez, Esquire Fla.Bar No.. 1002990 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone:(954) 370-9970 Facsimile: (954) 382-1988 Attorneys for Defendants Address for service of pleadingsonly aneifeld@kelleykronenberg.com rgonzalez@kelleykronenberg.com smaler@kelleykronenberg.com 2