Motion,Ex Parte: US BANK TRUST NATIONAL ASSOCIA vs TOWN OF WHITE SPRINGS FLORIDA et al

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                                Filing # MME          E-Filed 10/30/2023 02:24:30 PM



                        IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT
                               IN AND FOR HAMILTON COUNTY, FLORIDA
                                            CIVIL ACTION

      US BANK TRUST NATIONAL ASSOCIATION, ete.,                                                   CASE NO.: 2023CA41

               Plaintiff,

      Vv.


      RUBY T. WILLIAMS; et al.,

               Defendants.
                                                                /

                    DEFENDANT’S AMENDED MOTION FOR EXTENSION                                       OF TIME TO
                               RESPOND TO DISCOVERY REQUESTS

               Defendant,     Ruby     Williams     (“Defendant”),        by     and through     Defendant’s        undersigned

      counsel, move this Court for entry of an order granting Defendant an extension of time in

      accordance      with   Rule    1.090(b),    Florida     Rules    of Civil    Procedure,    in which      to    respond   to

      Plaintiff's First Request for Production to Defendants (collectively “Discovery Requests”) filed

      and/or served by Plaintiff, U.S. Bank Trust, N.A., ete. (“Plaintiff”), and as grounds therefore

      state:


               1        Defendant      needs     additional     time    within    which   to    review   and    formulate      an

      appropriate response to the Discovery Requests.

               2.       Defendant’s request for additional time is made in good faith and not for the

      purpose of delay. Plaintiff will not be prejudiced by an extension of time.

               WHEREFORE,             Defendant respectfully requests this Court to enter an order granting

      Defendant an extension of time to respond to the Discovery Requests and for such other and




      Electronically Filed Hamilton Case # 23000041CAAXMX 10/30/2023 02:24:30 PM
further relief as this Court deems appropriate.

Dated: October 30, 2023.
                                                  KYLE & KYLE LAW
                                                  Attorneys for Defendant
                                                  2241 N. Monroe St., #1096
                                                  Tallahassee, FL 32303
                                                  (850) 270-7604
                                                  john@kyleandkylelaw.com

                                                  By:    _4s/ John Lara
                                                         John Lara, Esq.
                                                         Florida Bar Number: 1041177

                                 CERTIFICATE OF SERVICE

       I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by

electronic mail or U.S. Mail on October 30, 2023, to:

Howard Law Group
4755 Technology Way, Suite 104
Boca Raton, FL 33431
pleadings@howardlaw.com
Attorneys for Plaintiff


                                                        4s/ John Lara
                                                        John Lara, Esq.