On November 19, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Stephens As Personal Representative Of The Estate Of Jessie O Walker Aka Jessie M Walker Deceased, Latonya A,
and
Bivens, Curtine,
Bivens Jr, Clarence W,
for Circuit Civil
in the District Court of Lake County.
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Filing # 184513415 E-Filed 10/23/2023 10:55:24 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,
v.
CLARENCE W. BIVENS (sic), JR. and
CURTINE BIVENS (sic),
Defendants.
___________________________________/
MOTION FOR EXTENSION OF TIME
COMES NOW the Defendants, CLARENCE BIVINS AND CURTINE BIVINS, by and
through the undersigned counsel, and files this Motion for Extension of Time, and in support
thereof states as follows:
1. On September 25, 2023, the Defendants were served with Request to Produce and
Interrogatories.
2. The Defendants’ response to same is due on or before October 25, 2023.
3. Pursuant to Fla.R.Civ.P. 1.090, the Defendants request an enlargement of time in
which to respond, as the discovery sought is extensive.
4. The granting of this Motion will not cause prejudice to either side in this case.
5. This Motion is made in good faith and not for the purpose of delay.
6. The undersigned counsel has made attempts to discuss the contents of said motion,
and other matters with opposing counsel, but has not received a response.
WHEREFORE, the Defendants respectfully requests that this court enter an Order
extending the time requirements for responding to Plaintiff’s Request to Produce and
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/23/2023 10:56:04 AM
Interrogatories.
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 23rd day of October 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
Document Filed Date
October 23, 2023
Case Filing Date
November 19, 2022
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Filing # 184513415 E-Filed 10/23/2023 10:55:24 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, v. CLARENCE W. BIVENS (sic), JR. and CURTINE BIVENS (sic), Defendants. ___________________________________/ MOTION FOR EXTENSION OF TIME COMES NOW the Defendants, CLARENCE BIVINS AND CURTINE BIVINS, by and through the undersigned counsel, and files this Motion for Extension of Time, and in support thereof states as follows: 1. On September 25, 2023, the Defendants were served with Request to Produce and Interrogatories. 2. The Defendants’ response to same is due on or before October 25, 2023. 3. Pursuant to Fla.R.Civ.P. 1.090, the Defendants request an enlargement of time in which to respond, as the discovery sought is extensive. 4. The granting of this Motion will not cause prejudice to either side in this case. 5. This Motion is made in good faith and not for the purpose of delay. 6. The undersigned counsel has made attempts to discuss the contents of said motion, and other matters with opposing counsel, but has not received a response. WHEREFORE, the Defendants respectfully requests that this court enter an Order extending the time requirements for responding to Plaintiff’s Request to Produce and FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 10/23/2023 10:56:04 AM Interrogatories. 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 23rd day of October 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