On May 28, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Jesus' Children,
and
Gruenstein, Shmily,
Haber, Paul,
Ryan, Gail,
United Yacht Transport Llc,,
for 3
in the District Court of Broward County.
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Filing# 171977554 E-Filed 04/27/2023 05:01:21 PM
IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.. CACE21010751-21
JESUS' CHILDREN
Plaintiff.
V
UNITED YACHT TRANSPORT, LLC, et al.
Defendants.
i
DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
PLAINTIFF'S REQUEST FOR PRODUCTION
Defendant, UNITED YACHT TRANSPORT, LLC, ("Defendant"),by and through the
undersigned counsel, hereby files this Motion for Enlargement of Time to Respond to Plaintiff
First Request for Production and in support states as follows:
Jesus Children's ("Plaintiff')
1. Plaintiff served Defendant United Yacht with a First Set Request for Production
on March 28,2023.
2. Defendants' responses to these discoveryrequests are due on or before April 27,
2023.
3 Defendants are in need of additional time in which to respond to these discovery
requests and are a requestingan extension of 30 days,through and includingMay 27,2023.
4. Undersigned counsel certifies that the relief requested herein is sought in good
faith and not for the purpose of delay or any other dilatorypurpose.
WHEREFORE, Defendant, UNITED YACHT TRANSPORT, LLC respectfully
requests
that this Court grant this Motion and enter an Order granting an enlargement of time within
000002/01450555 1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/27/2023 05:01:20 PM.****
CASE NO.: CACE21010751-21
which to file its response to Plaintiff's First Request for Production, and for any further relief the
Court deems justand proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
filed via the Court's
electronically system, (and a copy served upon counsel through the
e-filing
system),on this 27th day of April,2023.
Court's e-filing
KOPELOWITZ OSTROW
Ferguson Weiselberg Gilbert
AttorneysMDefendant
One West Las Olas Blvd., Suite 500
Fort Lauderdale, FL 33301
Telephone: (954) 525-4100; Fax (954) 525-4300
By: /s/ Benjamin R. Muschel
BENJAMIN R. MUSCHEL
Fla. Bar No. 119305
muschel@kolawyers.com
000002/01450555-1 2
Document Filed Date
April 27, 2023
Case Filing Date
May 28, 2021
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Filing# 171977554 E-Filed 04/27/2023 05:01:21 PM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.. CACE21010751-21 JESUS' CHILDREN Plaintiff. V UNITED YACHT TRANSPORT, LLC, et al. Defendants. i DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S REQUEST FOR PRODUCTION Defendant, UNITED YACHT TRANSPORT, LLC, ("Defendant"),by and through the undersigned counsel, hereby files this Motion for Enlargement of Time to Respond to Plaintiff First Request for Production and in support states as follows: Jesus Children's ("Plaintiff') 1. Plaintiff served Defendant United Yacht with a First Set Request for Production on March 28,2023. 2. Defendants' responses to these discoveryrequests are due on or before April 27, 2023. 3 Defendants are in need of additional time in which to respond to these discovery requests and are a requestingan extension of 30 days,through and includingMay 27,2023. 4. Undersigned counsel certifies that the relief requested herein is sought in good faith and not for the purpose of delay or any other dilatorypurpose. WHEREFORE, Defendant, UNITED YACHT TRANSPORT, LLC respectfully requests that this Court grant this Motion and enter an Order granting an enlargement of time within 000002/01450555 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/27/2023 05:01:20 PM.**** CASE NO.: CACE21010751-21 which to file its response to Plaintiff's First Request for Production, and for any further relief the Court deems justand proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed via the Court's electronically system, (and a copy served upon counsel through the e-filing system),on this 27th day of April,2023. Court's e-filing KOPELOWITZ OSTROW Ferguson Weiselberg Gilbert AttorneysMDefendant One West Las Olas Blvd., Suite 500 Fort Lauderdale, FL 33301 Telephone: (954) 525-4100; Fax (954) 525-4300 By: /s/ Benjamin R. Muschel BENJAMIN R. MUSCHEL Fla. Bar No. 119305 muschel@kolawyers.com 000002/01450555-1 2