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Filing # 107258397 E-Filed 05/08/2020 03:55:38 PM.
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL
CIRCUIT IN AND FOR MARION COUNTY, FLORIDA
THE FARMERS NATIONAL BANK OF DANVILLE,
a national banking association,
Plaintiff CIVIL DIVISION
CASE NO. 19-CA-2336
VS.
VICKI DELYS HYDE; and
JOHN DOE and JANE DOE, unknown parties in possession,
Defendants.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME
Plaintiff, THE FARMERS NATIONAL BANK OF DANVILLE, a national banking
association (“Plaintiff”), by and through their undersigned counsel, files this Motion for Extension
of Time, and as basis therefore, states as follows:
1 On or about February 18, 2020, VICKI DELYS HYDE (“Defendant”) filed and
served a Notice of Service of First Set of Interrogatories and First Request for Production of
Documents to Plaintiff.
2 On April 6, 2020, this Court granted Plaintiff's First Motion to Extend Plaintiffs
deadline to respond to Defendant’s discovery request.
3 Due to the COVID-19 outbreak, Plaintiff's officers and agents remain unable to
access their offices or the documents necessary to respond to Defendant’s production requests.
4. As a result of Plaintiff's ongoing inability to access the required documents and
information, and the Court’s closure, Plaintiff requests an extension of all deadlines, including
discovery deadlines (which may have already lapsed), until June 1, 2020 so that the undersigned
may review the matter, collect necessary documents, and appropriately respond to any outstanding
items.
5 Plaintiff has consulted Defendant’s counsel, who is not opposed to the requested
extension.
6 This relief is not requested for purposes of delay and would not result in prejudice
to any parties. Rather, to the extent the relief is not granted, Plaintiff's interests will be prejudiced.
WHEREFORE, Plaintiff respectfully requests that this Court grants an extension on all
deadlines, including discovery deadlines (which may have already lapsed), until June 1, 2020 so
that the undersigned can obtain and review the documents and responses requested in this matter,
and appropriately respond.
~)
Austin T. Dailey, Es
Florida Bar No.: 1011626
KLEIN & KLEIN, LLC
40 SE 11" Avenue
Ocala, FL 34471
Phone: (352) 732-7750
ustin@kleinandkleinpa.com
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
ANDREW D. FITZPATRICK, ESQUIRE, Haynes Law Group, P.A., Attorney for Defendant, 407
Wekiva Springs Road, Suite 217, Longwood, FL 32779, email: And hayneslegalgroup.com, via
electronic service through e-portal filing on this ¥ day of May, 2020.
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Filing # 107258397 E-Filed 05/08/2020 03:55:38 PM. IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA THE FARMERS NATIONAL BANK OF DANVILLE, a national banking association, Plaintiff CIVIL DIVISION CASE NO. 19-CA-2336 VS. VICKI DELYS HYDE; and JOHN DOE and JANE DOE, unknown parties in possession, Defendants. / PLAINTIFF’S MOTION FOR EXTENSION OF TIME Plaintiff, THE FARMERS NATIONAL BANK OF DANVILLE, a national banking association (“Plaintiff”), by and through their undersigned counsel, files this Motion for Extension of Time, and as basis therefore, states as follows: 1 On or about February 18, 2020, VICKI DELYS HYDE (“Defendant”) filed and served a Notice of Service of First Set of Interrogatories and First Request for Production of Documents to Plaintiff. 2 On April 6, 2020, this Court granted Plaintiff's First Motion to Extend Plaintiffs deadline to respond to Defendant’s discovery request. 3 Due to the COVID-19 outbreak, Plaintiff's officers and agents remain unable to access their offices or the documents necessary to respond to Defendant’s production requests. 4. As a result of Plaintiff's ongoing inability to access the required documents and information, and the Court’s closure, Plaintiff requests an extension of all deadlines, including discovery deadlines (which may have already lapsed), until June 1, 2020 so that the undersigned may review the matter, collect necessary documents, and appropriately respond to any outstanding items. 5 Plaintiff has consulted Defendant’s counsel, who is not opposed to the requested extension. 6 This relief is not requested for purposes of delay and would not result in prejudice to any parties. Rather, to the extent the relief is not granted, Plaintiff's interests will be prejudiced. WHEREFORE, Plaintiff respectfully requests that this Court grants an extension on all deadlines, including discovery deadlines (which may have already lapsed), until June 1, 2020 so that the undersigned can obtain and review the documents and responses requested in this matter, and appropriately respond. ~) Austin T. Dailey, Es Florida Bar No.: 1011626 KLEIN & KLEIN, LLC 40 SE 11" Avenue Ocala, FL 34471 Phone: (352) 732-7750 ustin@kleinandkleinpa.com Attorney for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to ANDREW D. FITZPATRICK, ESQUIRE, Haynes Law Group, P.A., Attorney for Defendant, 407 Wekiva Springs Road, Suite 217, Longwood, FL 32779, email: And hayneslegalgroup.com, via electronic service through e-portal filing on this ¥ day of May, 2020.