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  • LAPOSA, DEBRA vs. WAL-MART STORES EAST LPPremises Liability - Commercial document preview
  • LAPOSA, DEBRA vs. WAL-MART STORES EAST LPPremises Liability - Commercial document preview
  • LAPOSA, DEBRA vs. WAL-MART STORES EAST LPPremises Liability - Commercial document preview
  • LAPOSA, DEBRA vs. WAL-MART STORES EAST LPPremises Liability - Commercial document preview
						
                                

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Filing # 127212218 E-Filed 05/20/2021 01:53:47 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL ACTION DEBRA LAPOSA, Plaintiff, Case No. 2020-100-CA WAL-MART STORES EAST, L.P., a Foreign Limited Partnership, and RYAN BARBER, Store Manager, Defendants. / JOINT MOTION TO EXTEND DEADLINE TO COMPLETE MEDIATION COMES NOW Defendant, WAL-MART STORES EAST, L.P., along with Defendant, RYAN BARBER, and Plaintiff, DEBRA LAPOSA, by and through their undersigned counsel, moves that this Honorable Court enter an Order extending the deadline for completion of Mediation, pursuant to this Court's Agreed Case Management Plan and Order entered on June 4, 2020, and as grounds therefore would state as follows: 1 This is an action for personal injury filed against the Defendants on January 31, 2020 arising from a slip and fall incident that allegedly took place on August 2, 2016. 2 Pursuant to the Court's Agreed Case Management Plan and Order, the deadline to complete Mediation was March 3, 2021. 3. Counsel for all parties have agreed to extend the current deadline to accommodate all parties expected to attend the Mediation, currently scheduled to take place on June 18, 2021. 4 The parties have agreed to appoint David Horvath, Esq. as the Mediator in this matter. 5. All parties agree to this extension and no party will be prejudiced by the Court granting this Agreed Motion to Extend Deadline to Complete Mediation. WHEREFORE, it is respectfully requested that this Honorable Court enter an Order extending the deadline to complete Mediation, to take place on June 18, 2021. CERTIFICATE OF SERVICE | HEREBY CERTIFY that I electronically filed the foregoing with the Clerk of Court using the E-Filing Portal System which will send a notice of electronic filing to the following: Ashley Long, Esquire Morgan & Morgan, P.A. 2222 South Tamiami Trail Sarasota, FL 34239 Telephone: 941.366.1790 Facsimile: 941.366.6063 lon ‘orthepeople.com Attorneys for Plaintiff this 20" day of May, 2021 HENDERSON, FRANKLIN, STARNES & HOLT, P.A. Attorneys for Defendant, Walmart Stores East, LP Post Office Box 280 1715 Monroe Street Fort Myers, FL 33902-0280 Telephone: 239.344.1249 Facsimile: 239.344.1542 By: siMadisowA. Tanner AMANDA J. ROSS, ESQUIRE Florida Bar No. 598666 manda.ross@henlaw.com tracey.salerno@henlaw.com MADISON A. TANNER, ESQUIRE Florida Bar No. 1011247 madison.tanner@henlaw.com usan.peters@henlaw.com