On August 24, 2021 a
Motion for Extension of Time
was filed
involving a dispute between
Strike C, Llc,
Strike X Llc,
and
Gulfstream Park Racing Association Inc,
Stronach, Belinda,
Village At Gulfstream Park, Llc,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing# 168434252 E-Filed 03/09/2023 06:39:40 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
CASE NO. CACE21016240
STRIKE X LLC,
Plaintiff,
V
VILLAGE AT GULFSTREAM PARK,
LLC,
Defendant.
i
DEFENDANT BELINDA STRONACH'S UNOPPOSED MOTION
FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S
REQUESTS FOR PRODUCTION FOR PERSONAL JURISDICTION DISCOVERY
Defendant, Belinda Stronach ("Ms. by and through undersigned counsel,
Stronach"),1
hereby moves pursuant to Florida Rule of Civil Procedure 1.350 for a brief enlargement of time,
through and includingMarch 13, 2023, within which to respond and objectto Plaintiff,
Strike X
LLC's ("Plaintiff')
Request for Production for Personal Jurisdiction ("Motion").In support ofthis
Motion, Ms. Stronach states as follows:
1. Plaintiffhas sued Ms. Stronach in her individual capacity.
Ms. Stronach, a Canadian
citizen domiciled in Toronto has moved to dismiss the Second Amended Complaint againsther
for lack and for failure
of personaljurisdiction to state a claim.
2. On February 7,2023, Plaintiff served Requests for Production to Ms. Stronach as
part of limited personaljurisdiction
discovery("Jurisdictional
RFP"). Ms. Stronach's response and
objectionis currentlydue on Thursday, March 9,2023.
1
Ms. Stronach reserves all rightsregardingher challengeto in-personamjurisdiction.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2023 06:39:40 PM.****
3 Due to the press of other work, undersigned counsel requiresadditional time to
prepare a response to the Jurisdictional RFP, which has 39 requests. On reflection,a brief four-day
enlargement is necessary.
4. Undersigned counsel soughtthe consent of the Plaintiff for an enlargementthrough
Monday, March 13, 2023. Plaintiff does not objectto the reliefrequested.
5. The requestedenlargement is made in good faith and not for purposes of delay. The
partieswill not be prejudicedby the brief relief requested.
WHEREFORE, Ms. Stronach respectfully
requests the Court enter an order extending the
time by which she must respond and objectto the Jurisdictional Requests for Production through
and includingMarch 13, 2023, and grantingMs. Stronach such other relief as is justand proper.
Respectfullysubmitted,
GREENBERG TRAURIG, P.A.
333 S.E. 2ind Avenue, Suite 4400
Miami, Florida 33131
Telephone: (305) 579-0519
Facsimile: (305) 579-0717
By: s/Michael N. Kreitzer
Michael N. Kreitzer, Esq.
Florida Bar No. 705561
kreitzerm@gtlaw.com
belloy@gtlaw.com
flservice@gtlaw.com
Jennifer J. Junger, Esq.
Florida Bar No. 125853
jungerj@gtlaw.com
fernandezfe@gtlaw.com
Jordanna Ishmael, Esq.
Florida Bar No. 1011647
ishmaelj@gtlaw.com
abrahamd@gtlaw.com
Attorneysfor Villageat Gulfstream Park, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served by e-mail via
the Florida Court E-FilingPortal,this 9th day of March, 2023, on:
ZARCO EINHORN SALKOWSKI & BRITO, P.A.
One Biscayne Tower
2 South Biscayne Boulevard, 34th Floor
Miami, Florida 33131
Telephone: (305) 374-5418
Facsimile: (305) 374-5428
Robert Zarco
Florida Bar No. 502138
rzarco@zarcolaw.com
Robert F. Salkowski
Florida Bar No. 903124
rsalkowski@zarcolaw.com
acoro@zarcolaw.com
Mary Nikezic
Florida Bar No. 92928
mnikezic@zarcolaw.com
eservice@zarcolaw.com
By: s/Michael N. Kreitzer
Document Filed Date
March 09, 2023
Case Filing Date
August 24, 2021
Category
Contract and Indebtedness
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Filing# 168434252 E-Filed 03/09/2023 06:39:40 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION CASE NO. CACE21016240 STRIKE X LLC, Plaintiff, V VILLAGE AT GULFSTREAM PARK, LLC, Defendant. i DEFENDANT BELINDA STRONACH'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S REQUESTS FOR PRODUCTION FOR PERSONAL JURISDICTION DISCOVERY Defendant, Belinda Stronach ("Ms. by and through undersigned counsel, Stronach"),1 hereby moves pursuant to Florida Rule of Civil Procedure 1.350 for a brief enlargement of time, through and includingMarch 13, 2023, within which to respond and objectto Plaintiff, Strike X LLC's ("Plaintiff') Request for Production for Personal Jurisdiction ("Motion").In support ofthis Motion, Ms. Stronach states as follows: 1. Plaintiffhas sued Ms. Stronach in her individual capacity. Ms. Stronach, a Canadian citizen domiciled in Toronto has moved to dismiss the Second Amended Complaint againsther for lack and for failure of personaljurisdiction to state a claim. 2. On February 7,2023, Plaintiff served Requests for Production to Ms. Stronach as part of limited personaljurisdiction discovery("Jurisdictional RFP"). Ms. Stronach's response and objectionis currentlydue on Thursday, March 9,2023. 1 Ms. Stronach reserves all rightsregardingher challengeto in-personamjurisdiction. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/09/2023 06:39:40 PM.**** 3 Due to the press of other work, undersigned counsel requiresadditional time to prepare a response to the Jurisdictional RFP, which has 39 requests. On reflection,a brief four-day enlargement is necessary. 4. Undersigned counsel soughtthe consent of the Plaintiff for an enlargementthrough Monday, March 13, 2023. Plaintiff does not objectto the reliefrequested. 5. The requestedenlargement is made in good faith and not for purposes of delay. The partieswill not be prejudicedby the brief relief requested. WHEREFORE, Ms. Stronach respectfully requests the Court enter an order extending the time by which she must respond and objectto the Jurisdictional Requests for Production through and includingMarch 13, 2023, and grantingMs. Stronach such other relief as is justand proper. Respectfullysubmitted, GREENBERG TRAURIG, P.A. 333 S.E. 2ind Avenue, Suite 4400 Miami, Florida 33131 Telephone: (305) 579-0519 Facsimile: (305) 579-0717 By: s/Michael N. Kreitzer Michael N. Kreitzer, Esq. Florida Bar No. 705561 kreitzerm@gtlaw.com belloy@gtlaw.com flservice@gtlaw.com Jennifer J. Junger, Esq. Florida Bar No. 125853 jungerj@gtlaw.com fernandezfe@gtlaw.com Jordanna Ishmael, Esq. Florida Bar No. 1011647 ishmaelj@gtlaw.com abrahamd@gtlaw.com Attorneysfor Villageat Gulfstream Park, LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served by e-mail via the Florida Court E-FilingPortal,this 9th day of March, 2023, on: ZARCO EINHORN SALKOWSKI & BRITO, P.A. One Biscayne Tower 2 South Biscayne Boulevard, 34th Floor Miami, Florida 33131 Telephone: (305) 374-5418 Facsimile: (305) 374-5428 Robert Zarco Florida Bar No. 502138 rzarco@zarcolaw.com Robert F. Salkowski Florida Bar No. 903124 rsalkowski@zarcolaw.com acoro@zarcolaw.com Mary Nikezic Florida Bar No. 92928 mnikezic@zarcolaw.com eservice@zarcolaw.com By: s/Michael N. Kreitzer