Motion,Ex Parte: Brett Katchmere Plaintiff vs. Francisco Colet, et al Defendant

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                                Filing# 165117472 E-Filed 01/20/2023 11:07:25                      AM

                                                                        INTHE CIRCUIT COURT OF THE 17TH
                                                                        JUDICIAL CIRCUIT IN AND FOR
                                                                        BROWARD COUNTY, FLORIDA
                                                                        CASE NO.:       CACE-21-007713 (08)

        VICKI KATCHMERE,

                  Plaintiff,

        V

        MEADOWBROOK LAKES VIEW
        CONDOMINIUM ASSOCIATION"A",                          INC.,
        a Florida Not-For-Profit Corporation,and
        FRANCISCO COLET,

                  Defendants.
                                                               i



                          FRANCISCO COLET'S MOTION FOR EXTENSION OF TIME
                                     TO FILE FACT WITNESS LIST

                  Defendant,   FRANCISCO COLET,                through undersigned counsel, hereby      files his   Motion

        for Extension      of Time to   file                        and in support thereof states as follows:
                                               his Fact witness list,




                  1.       On November          15, 2022, the Court entered an order resettingTrial and requiring


        that a Fact Witness List be filed           by January 26,2023.


                  2.       This   file was   being handled primarilyby Peter K. Buckley, Esq.,a former associate

        at   Vincent F. Vaccarella, P.A.



                  3        Mr. Buckley       left   the firm on January 13, 2023.




                  4.       The undersigned law firm has a privatetrial              that will   be occurring during the

        remainder o f January and throughoutthe month of February.




             *** FILED:   BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/20/2023                     11:07:25   AM.****
        5.         As   a result, the undersigned law             firm requests          an extension of time for

FRANCISCO COLET to           file his   Fact Witness List while the firm reassignsthe case, allows that


                                            and prepares for the aforementioned
attorney to familiarize itself with the file,                                                      trial.




        6.         Accordingly,the undersignedrequests a brief thirty(30) day extension.



        7.         Additionally,due to other pending personal and professionalresponsibilities,


includingthe extension of thirty(30)days within which to                 file   Colet's Fact witness        list.




        8          This Request   is   made   in   good   faith   and not for the purposes of delay and no


prejudicewill be suffered by the grantingof this Motion.

        WHEREFORE,           Defendant,    FRANCISCO COLET,                   hereby requests     this   Court to grant


him a thirty(30) day extension of time         in    which                                and for such further
                                                             to file his Fact witness list,


relief as this   Court deems just,equitable,
                                           and proper.



                                       CERTIFICATE OF SERVICE

        WE HEREBY CERTIFY that a true                     and correct copy of the foregoing was served via
                                               .th
Electronic Mail (and E-portal)on this 20I day o f January 2023 to                  all   counsel o f record.




                                                                  VINCENT F. VACCARELLA, P.A.
                                                                  Counsel for Francisco Colet
                                                                  888 E. Las Olas Blvd, Suite 700
                                                                  Fort Lauderdale, Florida 33301

                                                                  Telephone:(305)932-4044
                                                                                932-4990
                                                                  Facsimile:(305)



                                                                  By:   /s/   Vincent F. Vaccarella
                                                                    VINCENT F. VACCARELLA
                                                                    Fla.      Bar No.017426
                                                                    vincent@v-law.net