On June 03, 135 a
Motion,Ex Parte
was filed
involving a dispute between
Gonzalez, Barbara,
and
Edwards, Michael G,
Hhs Environmental Services, Llc,
for Other - Matters not within the Other Negligence Subcategories
in the District Court of Charlotte County.
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Filing # 185089695 E-Filed 10/30/2023 05:18:37 PM
IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
BARBARA GONZALEZ,
CASE NO.: 21000968CA
Plaintiff,
V.
MICHAEL G. EDWARDS and
HHS ENVIRONMENTAL SERVICES, LLC and
PORT CHARLOTTE HMA, LLC d/b/a
SHOREPOINT HEALTH PORT CHARLOTTE,
f/k/a BAYFRONT HEALTH PORT CHARLOTTE,
Defendants.
/
DEFENDANTS, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES,
LLC MOTION FOR EXTENS: FF TIME TO RESPOND TO PLAINTIF! TFTH
REQUEST FOR PRODUCTION
COMES NOW, Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL
SERVICES, LLC. by and through undersigned counsel, hereby file their Motion for Extension of
Time to Respond to Plaintiff's Fifth Request for Production and as grounds therefore, states as
follows:
1 On September 28, 2023, Plaintiff served their Fifth Request for Production on
Defendants.
2 Defendants’ responses to Plaintiff's Fifth Request for Production are due on
October 30, 2023.
3 Defendants are requesting a twenty (20) day extension, in which to respond to
Plaintiff's Fifth Request for Production on Defendants.
4 The Defendants do not waive any objections to the discovery.
Kubicki Draper + 9100 S. DADELAND BLVD., SUITE 1800 MIAMI, FL 33156 + T: (305) 374-1212 + F: (305) 374-7846
5 This extension is not sought for purposes of causing prejudice or undue delay and
will not prejudice any party to this lawsuit.
WHEREFORE, Defendants respectfully requests this Honorable Court to grant the relief
requested herein or any other relief deemed just and proper.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all
counsel of record on the attached Service List this 30th day of October, 2023.
KUBICKI DRAPER
9100 South Dadeland Blvd.
Suite 1800
Miami, FL 33156
Telephone: (305) 982-6604
Facsimile: (305) 374-7846
Pleadings: FIC-KD@kubickidraper.com
By:_/s/ Francesca Ippolito-Craven
FRANCESCA IPPOLITO-CRAVEN
fic@kubickidraper.com
Florida Bar Number: 0145361
JESSICA M. DEL SOL
jmd@kubickidraper.com
Florida Bar Number: 1031645
SERVICE LIST
Counsel for Plaintiff:
Helen Stratigakos, Esq.
STRATIGAKOS LAW, P.A.
412 East Madison Street, Suite 814
Tampa, FL 33602
Primary: Helen@stratigakoslaw.com
Secondary: admin@stratigakoslaw.com
Co-counsel for Plaintiff:
Michael J. Rossi, Esq.
MICHAEL J. ROSSI, P.A.
115 South Albany Avenue
Tampa, FL 33606
michael@michaelrossilaw.com
Kubicki Draper + 9100 S. DADELAND BLVD., SUITE 1800 MIAMI, FL 33156 + T: (305) 374-1212 + F: (305) 374-7846
Document Filed Date
October 30, 2023
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 185089695 E-Filed 10/30/2023 05:18:37 PM IN THE CIRCUIT COURT FOR THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIRCUIT CIVIL DIVISION BARBARA GONZALEZ, CASE NO.: 21000968CA Plaintiff, V. MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC and PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT CHARLOTTE, f/k/a BAYFRONT HEALTH PORT CHARLOTTE, Defendants. / DEFENDANTS, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC MOTION FOR EXTENS: FF TIME TO RESPOND TO PLAINTIF! TFTH REQUEST FOR PRODUCTION COMES NOW, Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC. by and through undersigned counsel, hereby file their Motion for Extension of Time to Respond to Plaintiff's Fifth Request for Production and as grounds therefore, states as follows: 1 On September 28, 2023, Plaintiff served their Fifth Request for Production on Defendants. 2 Defendants’ responses to Plaintiff's Fifth Request for Production are due on October 30, 2023. 3 Defendants are requesting a twenty (20) day extension, in which to respond to Plaintiff's Fifth Request for Production on Defendants. 4 The Defendants do not waive any objections to the discovery. Kubicki Draper + 9100 S. DADELAND BLVD., SUITE 1800 MIAMI, FL 33156 + T: (305) 374-1212 + F: (305) 374-7846 5 This extension is not sought for purposes of causing prejudice or undue delay and will not prejudice any party to this lawsuit. WHEREFORE, Defendants respectfully requests this Honorable Court to grant the relief requested herein or any other relief deemed just and proper. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was e-mailed to all counsel of record on the attached Service List this 30th day of October, 2023. KUBICKI DRAPER 9100 South Dadeland Blvd. Suite 1800 Miami, FL 33156 Telephone: (305) 982-6604 Facsimile: (305) 374-7846 Pleadings: FIC-KD@kubickidraper.com By:_/s/ Francesca Ippolito-Craven FRANCESCA IPPOLITO-CRAVEN fic@kubickidraper.com Florida Bar Number: 0145361 JESSICA M. DEL SOL jmd@kubickidraper.com Florida Bar Number: 1031645 SERVICE LIST Counsel for Plaintiff: Helen Stratigakos, Esq. STRATIGAKOS LAW, P.A. 412 East Madison Street, Suite 814 Tampa, FL 33602 Primary: Helen@stratigakoslaw.com Secondary: admin@stratigakoslaw.com Co-counsel for Plaintiff: Michael J. Rossi, Esq. MICHAEL J. ROSSI, P.A. 115 South Albany Avenue Tampa, FL 33606 michael@michaelrossilaw.com Kubicki Draper + 9100 S. DADELAND BLVD., SUITE 1800 MIAMI, FL 33156 + T: (305) 374-1212 + F: (305) 374-7846