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Filing # 29168755 E-Filed 07/01/2015 02:07:28 PM
IN THE CIRCUIT COURT OF THE 15"
JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: 50-2014 CA 000475 XXXX MB (AN)
JOSEPH BOAN
Plaintiff,
vs.
ANDREW LITVAK and HARTMAN,
SIMONS & WOOD, LLP,
Defendants.
/
DEFENDANTS’ MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT
The Defendants, ANDREW LITVAK (“LITVAK”) and HARTMAN SIMONS &
WOOD, LLP (“HSW’) (collectively “Defendants”), by and through their undersigned
counsel, hereby move this Court, pursuant to Rule 1.090 of the Florida Rules of Civil
Procedure, for the entry of an order enlarging the time within which to respond to
Plaintiffs, JOSEPH M. BOAN (‘Plaintiff’), Second Amended Complaint for Damages
(“Second Amended Complaint’). In support thereof, Defendants state:
41. On June 23, 2015, upon receiving leave of Court, Plaintiff served upon
Defendants his Second Amended Complaint; accordingly, Defendants’ response thereto
is due on or before July 6, 2015."
7 The deadline actually falls on July 3, 2015. However, because that is a Court observed holiday,
the deadline becomes July 6".
DEMAHY | LABRADOR [ DRAKE VICTOR | CABEZA
didlawyers.com
4 FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 7/1/2015 2:07:28 PM ***CASE NO.: 50-2014 CA 000475 XXXX MB (AN)
Page 2 of 3
2. Due to the undersigned’s schedule and caseload, an enlargement of time
is necessary in order to prepare an adequate response to Plaintiffs Second Amended
Complaint.
3. Defendants and their undersigned counsel hereby certify that this Motion
is being made in good faith and not for purposes of delay.
4. Moreover, Plaintiff will not be prejudiced by the relief being sought herein;
indeed, this matter is still in the pleading stages.
WHEREFORE, the Defendants, ANDREW LITVAK and HARTMAN, SIMONS &
WOOD, LLP, respectfully requests that this Court enter an order enlarging the time
within which to respond to Plaintiffs, JOSEPH M. BOAN, Second Amended Complaint
for Damages, and awarding such further relief as this Court deems just and proper.
DEMAHY LABRADOR DRAKE VICTOR & CABEZA
Attorneys for the Defendants
150 Alhambra Circle
Coral Gables, Florida 33134
Telephone: (305) 443-4850
Facsimile: (305) 443-5960
By:
Pete L-DeMahy, Esquire
Florida Bar Number: 241822
E-Mail: pdemahy@dldiawyers.com
Orlando D. Cabeza
Florida Bar Number: 933521
E-Mail: odcabeza@dlidlawyers.com
DEMAHY | LABRADOR | DRAKE | VICTOR | CABEZA
didiawyers.comCASE NO.: 50-2014 CA 000475 XXXX MB (AN)
Page 3 of 3
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregeina has been
furnished via E-Mail Only (Primary: selzmuvdi@aol.com) on this day of July,
2015, to Steven M. Selz, Esq., Selz & Muvdi Selz, P.A., Counsel for Plaintiff, 500
University Boulevard, Suite 110, Jupiter, Florida 33458.
rlando D. Cabeza
DEMAHY | LABRADOR | DRAKE I VICTOR f CABEZA
didlawyars.com
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Filing # 29168755 E-Filed 07/01/2015 02:07:28 PM IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: 50-2014 CA 000475 XXXX MB (AN) JOSEPH BOAN Plaintiff, vs. ANDREW LITVAK and HARTMAN, SIMONS & WOOD, LLP, Defendants. / DEFENDANTS’ MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT The Defendants, ANDREW LITVAK (“LITVAK”) and HARTMAN SIMONS & WOOD, LLP (“HSW’) (collectively “Defendants”), by and through their undersigned counsel, hereby move this Court, pursuant to Rule 1.090 of the Florida Rules of Civil Procedure, for the entry of an order enlarging the time within which to respond to Plaintiffs, JOSEPH M. BOAN (‘Plaintiff’), Second Amended Complaint for Damages (“Second Amended Complaint’). In support thereof, Defendants state: 41. On June 23, 2015, upon receiving leave of Court, Plaintiff served upon Defendants his Second Amended Complaint; accordingly, Defendants’ response thereto is due on or before July 6, 2015." 7 The deadline actually falls on July 3, 2015. However, because that is a Court observed holiday, the deadline becomes July 6". DEMAHY | LABRADOR [ DRAKE VICTOR | CABEZA didlawyers.com 4 FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 7/1/2015 2:07:28 PM ***CASE NO.: 50-2014 CA 000475 XXXX MB (AN) Page 2 of 3 2. Due to the undersigned’s schedule and caseload, an enlargement of time is necessary in order to prepare an adequate response to Plaintiffs Second Amended Complaint. 3. Defendants and their undersigned counsel hereby certify that this Motion is being made in good faith and not for purposes of delay. 4. Moreover, Plaintiff will not be prejudiced by the relief being sought herein; indeed, this matter is still in the pleading stages. WHEREFORE, the Defendants, ANDREW LITVAK and HARTMAN, SIMONS & WOOD, LLP, respectfully requests that this Court enter an order enlarging the time within which to respond to Plaintiffs, JOSEPH M. BOAN, Second Amended Complaint for Damages, and awarding such further relief as this Court deems just and proper. DEMAHY LABRADOR DRAKE VICTOR & CABEZA Attorneys for the Defendants 150 Alhambra Circle Coral Gables, Florida 33134 Telephone: (305) 443-4850 Facsimile: (305) 443-5960 By: Pete L-DeMahy, Esquire Florida Bar Number: 241822 E-Mail: pdemahy@dldiawyers.com Orlando D. Cabeza Florida Bar Number: 933521 E-Mail: odcabeza@dlidlawyers.com DEMAHY | LABRADOR | DRAKE | VICTOR | CABEZA didiawyers.comCASE NO.: 50-2014 CA 000475 XXXX MB (AN) Page 3 of 3 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregeina has been furnished via E-Mail Only (Primary: selzmuvdi@aol.com) on this day of July, 2015, to Steven M. Selz, Esq., Selz & Muvdi Selz, P.A., Counsel for Plaintiff, 500 University Boulevard, Suite 110, Jupiter, Florida 33458. rlando D. Cabeza DEMAHY | LABRADOR | DRAKE I VICTOR f CABEZA didlawyars.com