On May 18, 2023 a
Order
was filed
involving a dispute between
Black, Kerine,
and
Global Unity Care Inc.,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 194218315 E-Filed 03/18/2024 11:41:09 AM
IN THE COUNTY COURT
IN AND FOR OSCEOLA
COUNTY, FLORIDA
KERINE BLACK
Plaintiff, CASE NO.: 2023 CC 2141EV
vs
GLOBAL UNITY CARE INC.
Defendant(s)
_______________________/
MOTION TO RECONSIDER THE ORDER TO CHANGE VENUE
The plaintiff represents Kerine black hereby request a reconsideration of the order
granting the change of venue by the court on March 6, 2024, in consideration on the following:
1. A hearing was not requested or granted before the order by the court to change venue.
2. On 1/22 at 10:03 AM the plaintiff filed a motion for default on final judgement on
count 2 as the defendant has not responded since granted extension on October
27,2023.
3. The defendant responded on 1/22/2024 at 10:50AM with an answer and counter
claim with several allegations on independent contracts without proof of rental
payment. The fees to this counter claim were unpaid until February 21, 2024.
4. On the same date 1/22/ 2024 at 10:52AM the defendant filled a motion to transfer
venue
5. Both above requests from the defendant attorney were served to the plaintiff on
February 2, 2024.
6. On 2/14 the plaintiff filed a motion to dismiss the counter claim and request a
hearing. No response was granted to that request for a hearing.
7. On February 17 a notice unavailability was filed out by the defendant’s attorney for
any hearing from May 1, 2023, to August 1, 2024. And that no hearing or any other
matter pertaining to this case be scheduled at that time.
8. Here now, an order has been granted to the defendant’s request to change venue
without notification to the plaintiff or any hearing on the cause.
Page 1|2
WHEREFORE, the plaintiff hereby requests the reconsider of the order granted on March 6th,
2024, to move the case and request a hearing to this matter.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via Florida
Eportal to Andrew Doyle, Esq, counsel for the defendant this 8 day of March 8 2024.
_/s Kerine Black___
KERINE BLACK
Landlord
3445 Woodberry Ct, Kissimmee FL
phone: 813 398 2023
Email 1: Kerineblack@yahoo.com
Email 2: Enirekllc@gmail.com
PLAINTIFF
Page 2|2
Document Filed Date
March 18, 2024
Case Filing Date
May 18, 2023
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Filing # 194218315 E-Filed 03/18/2024 11:41:09 AM IN THE COUNTY COURT IN AND FOR OSCEOLA COUNTY, FLORIDA KERINE BLACK Plaintiff, CASE NO.: 2023 CC 2141EV vs GLOBAL UNITY CARE INC. Defendant(s) _______________________/ MOTION TO RECONSIDER THE ORDER TO CHANGE VENUE The plaintiff represents Kerine black hereby request a reconsideration of the order granting the change of venue by the court on March 6, 2024, in consideration on the following: 1. A hearing was not requested or granted before the order by the court to change venue. 2. On 1/22 at 10:03 AM the plaintiff filed a motion for default on final judgement on count 2 as the defendant has not responded since granted extension on October 27,2023. 3. The defendant responded on 1/22/2024 at 10:50AM with an answer and counter claim with several allegations on independent contracts without proof of rental payment. The fees to this counter claim were unpaid until February 21, 2024. 4. On the same date 1/22/ 2024 at 10:52AM the defendant filled a motion to transfer venue 5. Both above requests from the defendant attorney were served to the plaintiff on February 2, 2024. 6. On 2/14 the plaintiff filed a motion to dismiss the counter claim and request a hearing. No response was granted to that request for a hearing. 7. On February 17 a notice unavailability was filed out by the defendant’s attorney for any hearing from May 1, 2023, to August 1, 2024. And that no hearing or any other matter pertaining to this case be scheduled at that time. 8. Here now, an order has been granted to the defendant’s request to change venue without notification to the plaintiff or any hearing on the cause. Page 1|2 WHEREFORE, the plaintiff hereby requests the reconsider of the order granted on March 6th, 2024, to move the case and request a hearing to this matter. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via Florida Eportal to Andrew Doyle, Esq, counsel for the defendant this 8 day of March 8 2024. _/s Kerine Black___ KERINE BLACK Landlord 3445 Woodberry Ct, Kissimmee FL phone: 813 398 2023 Email 1: Kerineblack@yahoo.com Email 2: Enirekllc@gmail.com PLAINTIFF Page 2|2