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Filing # 122358732 E-Filed 03/02/2021 04:38:07 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-21-003837
WILNER JEAN,
as Natural Parent/Legal Guardian of
GHISLAINE JEAN,
Plaintiff,
vs.
SCHOOL BOARD OF BROWARD COUNTY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF
TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Pursuant to Florida Rule of Civil Procedure 1.090, Defendant, School Board of Broward
County (“SBBC”), moves for an extension of time to respond to Plaintiff's Complaint,
(“Complaint”), and states:
1 Plaintiff's Complaint was served on the SBBC on March 1, 2021, and the SBBC’s
response to the Complaint is currently due on March 22, 2021.
2. Undersigned counsel was recently retained to defend this matter. As a result,
undersigned counsel has not yet received complete files, has not had the chance to review the
files, to analyze Plaintiff's claims, and/or to conduct an independent investigation of Plaintiff's
claims in order to respond to Plaintiff's Complaint.
3 Based on the foregoing, as well as the serious nature of Plaintiff’s allegations,
Defendant requires additional time to investigate and respond to Plaintiff's Complaint and
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#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/02/2021 04:38:07 PM.****
CASE NO.: CACE-21-003837
requests a 30-day extension of time, up to and including Wednesday, April 21, 2021, for SBBC
to respond to Plaintiff's Complaint.
4 This motion is made in good faith and not for the purpose of delay. Moreover, no
party will be prejudiced by the granting of the requested extension.
WHEREFORE Defendant respectfully requests that the Court grant School Board of
Broward County, an extension of time, up to and including Wednesday, April 21, 2021, within
which to respond to the Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via
electronic mail this 2nd day of March, 2021 Rick Ss Jacobs, Esq.,
litigation@millerandjacobs.com, tick@millerandjacobs.com, and hr@millerandjacobs.com,
MILLER & JACOBS, 1600 South Federal Highway, Suite 1101, Pompano Beach, Florida 33062.
GRAY|ROBINSON
Counsel for Defendant,
School Board of Broward County
333 S.E. 2"4 Avenue, Suite 3200
Miami, Florida 33131
Telephone: (305) 416-6880
Facsimile: (305) 416-6887
By: /s/ Anastasia Protopapadakis
Anastasia Protopapadakis, FBN 51426
Primary e-mail:
Anastasia.Protopapadakis@Gray-Robinson.com
Secondary e-mails:
Danieska.Cuarezma@Gray-Robinson.com
Lourdes.Federici@Gray-Robinson.com
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Preview
Filing # 122358732 E-Filed 03/02/2021 04:38:07 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-21-003837 WILNER JEAN, as Natural Parent/Legal Guardian of GHISLAINE JEAN, Plaintiff, vs. SCHOOL BOARD OF BROWARD COUNTY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Pursuant to Florida Rule of Civil Procedure 1.090, Defendant, School Board of Broward County (“SBBC”), moves for an extension of time to respond to Plaintiff's Complaint, (“Complaint”), and states: 1 Plaintiff's Complaint was served on the SBBC on March 1, 2021, and the SBBC’s response to the Complaint is currently due on March 22, 2021. 2. Undersigned counsel was recently retained to defend this matter. As a result, undersigned counsel has not yet received complete files, has not had the chance to review the files, to analyze Plaintiff's claims, and/or to conduct an independent investigation of Plaintiff's claims in order to respond to Plaintiff's Complaint. 3 Based on the foregoing, as well as the serious nature of Plaintiff’s allegations, Defendant requires additional time to investigate and respond to Plaintiff's Complaint and #43613758 v1 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/02/2021 04:38:07 PM.**** CASE NO.: CACE-21-003837 requests a 30-day extension of time, up to and including Wednesday, April 21, 2021, for SBBC to respond to Plaintiff's Complaint. 4 This motion is made in good faith and not for the purpose of delay. Moreover, no party will be prejudiced by the granting of the requested extension. WHEREFORE Defendant respectfully requests that the Court grant School Board of Broward County, an extension of time, up to and including Wednesday, April 21, 2021, within which to respond to the Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic mail this 2nd day of March, 2021 Rick Ss Jacobs, Esq., litigation@millerandjacobs.com, tick@millerandjacobs.com, and hr@millerandjacobs.com, MILLER & JACOBS, 1600 South Federal Highway, Suite 1101, Pompano Beach, Florida 33062. GRAY|ROBINSON Counsel for Defendant, School Board of Broward County 333 S.E. 2"4 Avenue, Suite 3200 Miami, Florida 33131 Telephone: (305) 416-6880 Facsimile: (305) 416-6887 By: /s/ Anastasia Protopapadakis Anastasia Protopapadakis, FBN 51426 Primary e-mail: Anastasia.Protopapadakis@Gray-Robinson.com Secondary e-mails: Danieska.Cuarezma@Gray-Robinson.com Lourdes.Federici@Gray-Robinson.com #43613758 v1