On January 16, 100 a
Motion-Secondary
was filed
involving a dispute between
V C A United Llc,
and
Integrated Vascular Imaging Llc,
Melissa L Hansler,
for OTHER CIRCUIT
in the District Court of Palm Beach County.
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Filing # 136024643 E-Filed 10/06/2021 01:16:11 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
V.C.A UNITED, LLC, CASE NO. 50-2020-CA-007471
Plaintiff,
vs.
MELISSA L. HANSLER; and INTEGRATED
VASCULAR IMAGING, LLC,
Defendants.
/
DEFENDANTS’ UNOPPOSED MOTION TO DEEM RESPONSE IN OPPOSITION TO
PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT TIMELY FILED
AND FOR E! RGEMENT OF TIME TO FILE RESPONSE IN OPPOSITION TO
PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT
Defendants MELISSA L. HANSLER (“Ms. Hansler”) and INTEGRATED VASCULAR
IMAGING, LLC (“IVI”) (collectively, “Defendants”) move to deem their Response in Opposition
to V.C.A UNITED, LLC’s (“Plaintiff”) Motion for Partial Summary Judgment (“Response”) as
timely filed and to enlarge time to file their Response, and state:
1. Defendants worked diligently to provide a Response due on October 5, 2021. The
Motion for Summary Judgment hearing is set for October 25, 2021. During the filing process, the
undersigned’s office encountered technical difficulties, including but not limited to an initial lack
of access to the efiling portal and system errors when uploading the Response due to the size of
the document.
2. The undersigned’s office was able to successfully upload the Response on October
6, at 12:09am.
3. Given that Florida’s new summary judgment rule requires the nonmovant to
respond at least twenty (20) days before the hearing, Defendants respectfully request the Court
accept and deem the Response as timely filed on October 5, 2021. Fla. R. Civ. P. 1.510(c)(5).
4. Plaintiff will not be prejudiced by the relief requested herein.
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 10/06/2021 01:16:11 PM ***5.
oppose the relief requested herein.
The undersigned’s office has conferred with Plaintiff's counsel who does not
WHEREFORE, Defendants Melissa Hansler and Integrated Vascular Images, LLC
respectfully request this Court deem their Response in Opposition to Plaintiff's Motion for Partial
Summary Judgment filed on October 5, 2021, and awarding further relief as the Court deems just
and proper
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been filed via
Florida ePortal and furnished via electronic mail on this 6th day of October 2021, to all counsel of
record.
Respectfully submitted,
THE MARKARIAN GROUP
Attorneys for Defendants
2925 PGA Boulevard, Suite 204
Palm Beach Gardens, Florida 33410
Telephone: (561) 626-4700
Facsimile: (561) 627-9479
By: /s/ David K. Markarian
David K. Markarian
Florida Bar No. 480691
Jessica R. Glickman
Florida Bar No. 118586
Alexandra S. Eichner
Florida Bar No. 1025384
Document Filed Date
December 13, 1988
Case Filing Date
January 16, 100
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Filing # 136024643 E-Filed 10/06/2021 01:16:11 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA V.C.A UNITED, LLC, CASE NO. 50-2020-CA-007471 Plaintiff, vs. MELISSA L. HANSLER; and INTEGRATED VASCULAR IMAGING, LLC, Defendants. / DEFENDANTS’ UNOPPOSED MOTION TO DEEM RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT TIMELY FILED AND FOR E! RGEMENT OF TIME TO FILE RESPONSE IN OPPOSITION TO PLAINTIFF’S MOTION FOR PARTIAL SUMMARY JUDGMENT Defendants MELISSA L. HANSLER (“Ms. Hansler”) and INTEGRATED VASCULAR IMAGING, LLC (“IVI”) (collectively, “Defendants”) move to deem their Response in Opposition to V.C.A UNITED, LLC’s (“Plaintiff”) Motion for Partial Summary Judgment (“Response”) as timely filed and to enlarge time to file their Response, and state: 1. Defendants worked diligently to provide a Response due on October 5, 2021. The Motion for Summary Judgment hearing is set for October 25, 2021. During the filing process, the undersigned’s office encountered technical difficulties, including but not limited to an initial lack of access to the efiling portal and system errors when uploading the Response due to the size of the document. 2. The undersigned’s office was able to successfully upload the Response on October 6, at 12:09am. 3. Given that Florida’s new summary judgment rule requires the nonmovant to respond at least twenty (20) days before the hearing, Defendants respectfully request the Court accept and deem the Response as timely filed on October 5, 2021. Fla. R. Civ. P. 1.510(c)(5). 4. Plaintiff will not be prejudiced by the relief requested herein. *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 10/06/2021 01:16:11 PM ***5. oppose the relief requested herein. The undersigned’s office has conferred with Plaintiff's counsel who does not WHEREFORE, Defendants Melissa Hansler and Integrated Vascular Images, LLC respectfully request this Court deem their Response in Opposition to Plaintiff's Motion for Partial Summary Judgment filed on October 5, 2021, and awarding further relief as the Court deems just and proper CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been filed via Florida ePortal and furnished via electronic mail on this 6th day of October 2021, to all counsel of record. Respectfully submitted, THE MARKARIAN GROUP Attorneys for Defendants 2925 PGA Boulevard, Suite 204 Palm Beach Gardens, Florida 33410 Telephone: (561) 626-4700 Facsimile: (561) 627-9479 By: /s/ David K. Markarian David K. Markarian Florida Bar No. 480691 Jessica R. Glickman Florida Bar No. 118586 Alexandra S. Eichner Florida Bar No. 1025384