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Filing # 60053053 E-Filed 08/07/2017 02:39:46 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY, FLORIDA
THE JOHN B. BUDNIK AND
ELIZABETH D. BUDNIK
REVOCABLE LIVING TRUST
DATED MARCH 9, 1992,
Plaintiff,
Vv. CASE NO, 2017 CA 1525 NC
BILL FURST, as Sarasota County
Property Appraiser, and LEON M.
BIEGALSKY, as Executive Director
of the Florida Department of Revenue,
Defendant.
/
MOTION FOR EXTENSION OF TIME
TO RESPOND TO REQUEST FOR PRODUCTION
Plaintiffs, THE JOHN B. BUDNIIS AND ELIZABETH D, BUDNIK REVOCABLE
LIVING TRUST DATED MARCH 9, 1992, moves for an extension of time within which to file
their Response to Defendant’s First Request for Production of Documents, and states as follows:
1. Despite their best efforts, Plaintiffs require additional time to compile all responsive
documents requested.
2. Plaintiffs therefore request an extension in order to file their responses,
3. The foregoing Motion is filed in good faith and not for dilatory or other improper
purposes, and no party will be preyudiced by an Order granting this Motion for Extension of Time.
WHEREFORE, Plaintiffs, THE JOHN B. BUDNIK AND ELIZABETH D. BUDNIK
REVOCABLE LIVING TRUST DATED MARCH 9, 1992, request this Court grant an
Filed 08/07/2017 03:16 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLextension in order to file their responses to Defendant’s First Request for Production of Documents
dated June 13, 2017.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically
filed with the Clerk of the Court of Sarasota County, Florida using the Florida Courts E-Filing
Portal and served on J. GEOFFREY PFLUGNER, ESQ., Icard , Merrill, Cullis, Timm, Furen &
Ginsburg, P.A., 2033 Main Street, Suite 600, Sarasota, FL 34237, at jptlugner@icardmerrill.com,
jlessinger(@icardmerrill.com, kmeilvenny@icardmerrill.com, miclinho@icarmerrill.com,
dmartin@icardmerrill.com on this _th-day of August, 2017,
BENTLEY & BRUNING, P.A.
andbruning.com
Florida Bar No, 0962287
AMANDA R., KISON, ESQ.
akison@bentlevandbruning.com
Florida Bar No. 096151
783 South Orange Avenue, 3" floor
Sarasota, Florida 34236
Telephone: (941) 556-9030
Facsimile: (941) 312-5316
Secondary. vengel@bentleyandbruning.com
Attorneys for Plaintiffs
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Filing # 60053053 E-Filed 08/07/2017 02:39:46 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA THE JOHN B. BUDNIK AND ELIZABETH D. BUDNIK REVOCABLE LIVING TRUST DATED MARCH 9, 1992, Plaintiff, Vv. CASE NO, 2017 CA 1525 NC BILL FURST, as Sarasota County Property Appraiser, and LEON M. BIEGALSKY, as Executive Director of the Florida Department of Revenue, Defendant. / MOTION FOR EXTENSION OF TIME TO RESPOND TO REQUEST FOR PRODUCTION Plaintiffs, THE JOHN B. BUDNIIS AND ELIZABETH D, BUDNIK REVOCABLE LIVING TRUST DATED MARCH 9, 1992, moves for an extension of time within which to file their Response to Defendant’s First Request for Production of Documents, and states as follows: 1. Despite their best efforts, Plaintiffs require additional time to compile all responsive documents requested. 2. Plaintiffs therefore request an extension in order to file their responses, 3. The foregoing Motion is filed in good faith and not for dilatory or other improper purposes, and no party will be preyudiced by an Order granting this Motion for Extension of Time. WHEREFORE, Plaintiffs, THE JOHN B. BUDNIK AND ELIZABETH D. BUDNIK REVOCABLE LIVING TRUST DATED MARCH 9, 1992, request this Court grant an Filed 08/07/2017 03:16 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLextension in order to file their responses to Defendant’s First Request for Production of Documents dated June 13, 2017. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been electronically filed with the Clerk of the Court of Sarasota County, Florida using the Florida Courts E-Filing Portal and served on J. GEOFFREY PFLUGNER, ESQ., Icard , Merrill, Cullis, Timm, Furen & Ginsburg, P.A., 2033 Main Street, Suite 600, Sarasota, FL 34237, at jptlugner@icardmerrill.com, jlessinger(@icardmerrill.com, kmeilvenny@icardmerrill.com, miclinho@icarmerrill.com, dmartin@icardmerrill.com on this _th-day of August, 2017, BENTLEY & BRUNING, P.A. andbruning.com Florida Bar No, 0962287 AMANDA R., KISON, ESQ. akison@bentlevandbruning.com Florida Bar No. 096151 783 South Orange Avenue, 3" floor Sarasota, Florida 34236 Telephone: (941) 556-9030 Facsimile: (941) 312-5316 Secondary. vengel@bentleyandbruning.com Attorneys for Plaintiffs