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Filing # 179751846 E-Filed 08/16/2023 08:56:28 AM
IN THE CIRCUIT COURT, OF
THE NINTH JUDICIAL CIRCUIT OF
FLORIDA IN AND FOR OSCEOLA
COUNTY
CASE NO.: 2023-CA-003864-OC
ASSOCIATION OF POINCIANA VILLAGES, INC.
a Florida not for-profit corporation,
Plaintiff,
vs.
THE HR GROUP LLC,
Defendant.
_____________________________________/
THE HR GROUP, LLC’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
AMENDED COMPLAINT
The Defendant, The HR Group, LLC, by and through its undersigned counsel, and pursuant
to the applicable Florida Rules of Civil Procedure, hereby moves the Court for an extension of
time to respond to the Amended Complaint served on Defendant, The HR Group, LLC, on
Thursday, July 20, 2023. In support thereof, The HR Group, LLC states as follows:
1. The Defendant was served with the Amended Complaint filed in this matter in July,
2023.
2. In response, Defendant retained the undersigned counsel, Carlton Fields, P.A., in
August, 2023.
3. The undersigned counsel is currently in the process of investigating the allegations
raised on the Amended Complaint which includes, without limitation, a review of documents
relevant to this dispute. The undersigned counsel needs additional time to assess the factual and
legal issues identified in the pleadings.
133769145.1
4. In light of the foregoing and in light of judicial economy, Defendant seeks an
extension of time until Friday, September 15, 2023 to respond to the Amended Complaint.
WHEREFORE, Defendant respectfully requests that the Court enter an Order granting
Defendant, HR Group, LLC, until Friday, September 15, 2023 to respond to the Amended
Complaint filed in this matter.
DATED: Wednesday, August 16, 2023 Respectfully Submitted,
/s/ Jason Perkins
Dara L. Lindquist, Esquire
Florida Bar No. 46172
Jason A. Perkins
Florida Bar Number 0610852
CARLTON FIELDS, P.A.
200 S. Orange Avenue, Ste. 1000
Orlando, Florida 32801
Telephone: (407) 849-0300
Facsimile: (407) 648-9099
Email: jperkins@carltonfields.com
Email: dlindquist@carltonfields.com
Email: dcarlucci@carltonfields.com
Email: orlecf@carltonfields.com
Attorneys for Defendant, The HR Group,
LLC, a Texas Limited Liability Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on August 16, 2023, the foregoing was filed with the Clerk of
the Court through Florida’s e-Portal, which will send an electronic notice of filing and service
copy of the foregoing to all registered users authorized to receive service of filings in the above
case.
/s/ Jason A. Perkins
Jason A. Perkins
2
133769145.1
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Filing # 179751846 E-Filed 08/16/2023 08:56:28 AM IN THE CIRCUIT COURT, OF THE NINTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR OSCEOLA COUNTY CASE NO.: 2023-CA-003864-OC ASSOCIATION OF POINCIANA VILLAGES, INC. a Florida not for-profit corporation, Plaintiff, vs. THE HR GROUP LLC, Defendant. _____________________________________/ THE HR GROUP, LLC’S MOTION FOR EXTENSION OF TIME TO RESPOND TO AMENDED COMPLAINT The Defendant, The HR Group, LLC, by and through its undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure, hereby moves the Court for an extension of time to respond to the Amended Complaint served on Defendant, The HR Group, LLC, on Thursday, July 20, 2023. In support thereof, The HR Group, LLC states as follows: 1. The Defendant was served with the Amended Complaint filed in this matter in July, 2023. 2. In response, Defendant retained the undersigned counsel, Carlton Fields, P.A., in August, 2023. 3. The undersigned counsel is currently in the process of investigating the allegations raised on the Amended Complaint which includes, without limitation, a review of documents relevant to this dispute. The undersigned counsel needs additional time to assess the factual and legal issues identified in the pleadings. 133769145.1 4. In light of the foregoing and in light of judicial economy, Defendant seeks an extension of time until Friday, September 15, 2023 to respond to the Amended Complaint. WHEREFORE, Defendant respectfully requests that the Court enter an Order granting Defendant, HR Group, LLC, until Friday, September 15, 2023 to respond to the Amended Complaint filed in this matter. DATED: Wednesday, August 16, 2023 Respectfully Submitted, /s/ Jason Perkins Dara L. Lindquist, Esquire Florida Bar No. 46172 Jason A. Perkins Florida Bar Number 0610852 CARLTON FIELDS, P.A. 200 S. Orange Avenue, Ste. 1000 Orlando, Florida 32801 Telephone: (407) 849-0300 Facsimile: (407) 648-9099 Email: jperkins@carltonfields.com Email: dlindquist@carltonfields.com Email: dcarlucci@carltonfields.com Email: orlecf@carltonfields.com Attorneys for Defendant, The HR Group, LLC, a Texas Limited Liability Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that on August 16, 2023, the foregoing was filed with the Clerk of the Court through Florida’s e-Portal, which will send an electronic notice of filing and service copy of the foregoing to all registered users authorized to receive service of filings in the above case. /s/ Jason A. Perkins Jason A. Perkins 2 133769145.1