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Filing # 127008228 E-Filed 05/18/2021 10:58:15 AM
1907.42233,
IN THE CIRCUIT COURT OF THE
15% JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO.: 2020 CA 011425 (AD)
J.-L. DOE, by and through her mother,
MOTHER DOE, as parent and legal guardian,
Plaintiff,
v.
PLACE OF HOPE, INC., a Florida not-for-profit corporation,
KIDSANCTUARY CAMPUS, INC., a Florida not-for-profit corporation,
the STATE OF FLORIDA DEPARTMENT OF CHILDREN AND
FAMILIES, a governmental department of the State of Florida, and
CHILDNET, INC., a Florida not-for-profit corporation,
Defendants.
NOTICE OF UNAVAILABILITY
PLEASE TAKE NOTICE that undersigned counsel for Defendants, PLACE OF HOPE, INC. and
KIDSANCTUARY CAMPUS, INC., will be unavailable on the following dates: June 16, 2021 through June
18, 2021, July 2, 2021 through July 12, 2021 and December 17, 2021 through January 3, 2022.
Respectfully, the undersigned requests that no hearings or discovery be scheduled during this period,
or other pleadings be filed which require a timely response during this time; and that pending matters remain
in status quo during this period of time, save and except for legitimate emergencies.
The filing and service of this Notice shall constitute an application and request for continuance,
extension of time and/or for protective order as required for the above reason.
CERTIFICATE OF SERVICE
1 certify that the foregoing document has been furnished to: Attorneys for the Plaintiff(s) - Seth M.
Lehrman, Esq.; Bradley J. Edwards, Esq. and Brittany N. Henderson, Esq. EDWARDS POTTINGER, LLC
(Brad @EPLLC.com; Brittanv@EPLLC.com and Seth@EPLLC.com) 425 North Andrews Avenue, Suite 2, Fort
Lauderdale, FL 33301; Attorneys for Co-Defendant, ChildNet, Inc. - Maritza Pena, Esq. and Renee Gomez, Esgq.,
MARLOW ADLER ABRAMS NEWMAN & LEWIS (MPena@MarlowAdler.com) 4000 Ponce De Leon Blvd, Suite 570,
Coral Gables, FL, 33146; Attorneys for Co-Defendant, State of Florida Department of Children and Families
— Karen M. Nissen, Esq, VERNIS & BOWLING OF PALM BEACH, P.A. (KNissen@BPlorida-Law.com;
CSchrader@Florida-Law.com and PBFiling@Blorida-Law.com), 884 U.S. Highway One, North Palm Beach, FL
33408; and Co-Counsel for Defendant, Place of Hope, Inc. and KidSanctuary Campus, Inc.— Ear! K. Mallory,
Esq, MALLORY LAW GRouP (EKM@MalloryLawGroup.com), 2074 West Indiantown Road, Suite 201, Jupiter, FL
33468 by e-mail and/or e-Portal on this 18" day of May, 2021.
Ls/ Miriam R. Mero
MIRIAM R. MERLO, EsqQ., Fla. Bar No. 027596
MMerlo@GaebeMullen.com
MGalan@GaebeMullen.com
GAEBE MULLEN ANTONELLI & DIMATTEO
Attorneys for PLACE OF HOPE & KIDSANCTUARY
420 South Dixie Highway, 3“ Floor
Coral Gables, FL 33146
Tel: (305) 667-0223 - Fax: (305) 284-9844
LAW OFFICES OF
Gaerne, MULLEN, ANTONELLI & DIMATTEO
** FILED: PALM BEACH COUNTY FE TOSEPEF ABRUZZO" CLERK 05/18/2021 10:58:15 AM ***
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Filing # 127008228 E-Filed 05/18/2021 10:58:15 AM 1907.42233, IN THE CIRCUIT COURT OF THE 15% JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO.: 2020 CA 011425 (AD) J.-L. DOE, by and through her mother, MOTHER DOE, as parent and legal guardian, Plaintiff, v. PLACE OF HOPE, INC., a Florida not-for-profit corporation, KIDSANCTUARY CAMPUS, INC., a Florida not-for-profit corporation, the STATE OF FLORIDA DEPARTMENT OF CHILDREN AND FAMILIES, a governmental department of the State of Florida, and CHILDNET, INC., a Florida not-for-profit corporation, Defendants. NOTICE OF UNAVAILABILITY PLEASE TAKE NOTICE that undersigned counsel for Defendants, PLACE OF HOPE, INC. and KIDSANCTUARY CAMPUS, INC., will be unavailable on the following dates: June 16, 2021 through June 18, 2021, July 2, 2021 through July 12, 2021 and December 17, 2021 through January 3, 2022. Respectfully, the undersigned requests that no hearings or discovery be scheduled during this period, or other pleadings be filed which require a timely response during this time; and that pending matters remain in status quo during this period of time, save and except for legitimate emergencies. The filing and service of this Notice shall constitute an application and request for continuance, extension of time and/or for protective order as required for the above reason. CERTIFICATE OF SERVICE 1 certify that the foregoing document has been furnished to: Attorneys for the Plaintiff(s) - Seth M. Lehrman, Esq.; Bradley J. Edwards, Esq. and Brittany N. Henderson, Esq. EDWARDS POTTINGER, LLC (Brad @EPLLC.com; Brittanv@EPLLC.com and Seth@EPLLC.com) 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301; Attorneys for Co-Defendant, ChildNet, Inc. - Maritza Pena, Esq. and Renee Gomez, Esgq., MARLOW ADLER ABRAMS NEWMAN & LEWIS (MPena@MarlowAdler.com) 4000 Ponce De Leon Blvd, Suite 570, Coral Gables, FL, 33146; Attorneys for Co-Defendant, State of Florida Department of Children and Families — Karen M. Nissen, Esq, VERNIS & BOWLING OF PALM BEACH, P.A. (KNissen@BPlorida-Law.com; CSchrader@Florida-Law.com and PBFiling@Blorida-Law.com), 884 U.S. Highway One, North Palm Beach, FL 33408; and Co-Counsel for Defendant, Place of Hope, Inc. and KidSanctuary Campus, Inc.— Ear! K. Mallory, Esq, MALLORY LAW GRouP (EKM@MalloryLawGroup.com), 2074 West Indiantown Road, Suite 201, Jupiter, FL 33468 by e-mail and/or e-Portal on this 18" day of May, 2021. Ls/ Miriam R. Mero MIRIAM R. MERLO, EsqQ., Fla. Bar No. 027596 MMerlo@GaebeMullen.com MGalan@GaebeMullen.com GAEBE MULLEN ANTONELLI & DIMATTEO Attorneys for PLACE OF HOPE & KIDSANCTUARY 420 South Dixie Highway, 3“ Floor Coral Gables, FL 33146 Tel: (305) 667-0223 - Fax: (305) 284-9844 LAW OFFICES OF Gaerne, MULLEN, ANTONELLI & DIMATTEO ** FILED: PALM BEACH COUNTY FE TOSEPEF ABRUZZO" CLERK 05/18/2021 10:58:15 AM ***