Motion,Ex Parte: STEPHENS AS PERSONAL REPRESENTATIVE OF THE ESTATE OF JESSIE O WALKER AKA JESSIE M WALKER DECEASED, LATONYA A vs BIVENS JR, CLARENCE W

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                                Filing # 163366542 E-Filed 12/20/2022 10:16:46 AM


                             IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
                                      IN AND FOR LAKE COUNTY, FLORIDA

            LATONYA STEPHENS, as Personal
            Representative of the Estate of
            JESSIE O. WALKER, a/k/a JESSIE M.
            Walker, deceased,                                              CASE NO: 2022-CA-002112

                    Plaintiff,

            Vv.


            CLARENCE W. BIVENS (sic), JR. and
            CURTINE BIVENS (sic),
                    Defendants.
                                                          /

                                          MOTION FOR EXTENSION OF TIME

                    COMES        NOW,   the Defendants, CLARENCE       BIVINS, JR. and CURTINE           BIVINS,

            (hereinafter referred to as “Defendants”), by and through the undersigned counsel, and pursuant to

            Fla.R.Civ.P, 1.090(b)(1)(B)   files this Motion for Extension of Time and in support thereof states:

                    1        On December 8, 2022, Defendants were served a Complaint.

                    2        The Defendants’ response is due December 28, 2022.

                    3        The Defendants retained the services of undersigned counsel on December 19,

            2022.

                    4        The Defendants are in need of additional time in which to meet with counsel, collect

            and review documents, and draft an appropriate response.

                    5        Given the impending holidays, the Plaintiff will not be unfairly prejudiced if

            Defendants are granted an additional thirty (30) days, nor will the granting of an extension result

            in undue delay of this proceeding.

                    6        This motion is made in good faith and not for dilatory purposes.




FILED: LAKE COUNTY, GARY J. COONEY, CLERK,                12/20/2022 10:31:20 AM
WHEREFORE, the Defendants, CLARENCE BIVINS, JR. and CURTINE BIVINS, pray

this Honorable Court will enter an Order enlarging the amount of time in which they must file an

Answer to January 27, 2023.



                                                BOYETTE, CUMMINS             & NAILOS, PLLC

                                                /s Michelle Bottex
                                                MICHELLE C. BOTTEX, ESQUIRE
                                                Florida Bar No: 15030
                                                1635 East Highway 50, Suite 300
                                                Clermont, Florida 34711
                                                Telephone: (352) 394-2103
                                                Facsimile: (352) 394-2105
                                                MBottex@BCNLawFirm.com
                                                Attorneys for Defendants

                                 CERTIFICATE OF SERVICE

        I HEREBY CERTIFY that I have furnished a true and correct copy of the foregoing via
Florida Courts E-filing Portal, to Joseph Shoemaker, Esq., Bogin, Munns, & Munns, @
jshoemaker@boginmunns.com; nschultz@boginmunns.com; and bmservice@boginmunns.com.
this 20 day of December, 2022.


                                                BOYETTE, CUMMINS & NAILOS, PLLC

                                                4s Michelle Bottex
                                                MICHELLE C. BOTTEX, ESQUIRE
                                                Florida Bar No:      15030
                                                1635 East Highway 50, Suite 300
                                                Clermont, Florida 34711
                                                Telephone: (352) 394-2103
                                                Facsimile: (352) 394-2105
                                                MBottex@BCNLawFirm.com
                                                Attorneys for Defendants