On September 29, 2020 a Motion,Ex Parte was filed involving a dispute between Ridge Top Exteriors Llc A Florida Limited Liability Company, and Parker, Elisabeth, Turpin, Matt S, for SMALL CLAIMS 4 - $2,501 - $5,000 in the District Court of Pinellas County.
April 12, 2021
September 29, 2020
SMALL CLAIMS 4 - $2,501 - $5,000
KRISTIN M RHODUS, ESQ Attorney for the Defendant
PARKER, ELISABETH Defendant
RIDGE TOP EXTERIORS LLC A FLORIDA LIMITED LIABILITY COMPANY Plaintiff
SEAN P COX, ESQ Attorney for the Plaintiff
TURPIN, MATT S Defendant
Gregory Krak Attorney
Ralph Leemis Attorney
Matthew Danahy Attorney
Andrew Rock Attorney
James Wardell Attorney
Stephen Barnes Attorney
John Trujillo Attorney
Anthony Martino Attorney
Arnold Levine Attorney
Gary Fiedler Attorney
Christopher Ligori Attorney
Robert Joyce Attorney
Roland Hermida Attorney
Omar Medina Attorney
Stuart Markman Attorney
Mark Septimus Attorney
Robert Oxendine Attorney
Edwin Valen Attorney
Tony Griffin Attorney
Julian Wood Attorney
Raymond Elligett Attorney
Dorothy DiFiore Attorney
Daniel Martinez Attorney
Weslee Ferron Attorney
Matthew Powell Attorney
Tonald Spinks Attorney
Anita DiGiacomo Attorney
R Melin Attorney
Patrick Dekle Attorneys for Defendants
Thomas Roehn Attorney
Wendy Accardi Attorney
Kimberly Lee Attorney
Howard Scholl Attorney
Jeffrey Liggio Attorney
Geoffrey Stahl Attorney
Curtis Wilson Attorney
Steve Tran Attorney
Peter Shapiro Attorney
Christopher Ranieri Attorney
William Allen Attorney
Simon Wiseman Attorney
Scott Turner Attorney
John Colvin Attorney
Coretta Anthony-Smith Attorney
Heather Harwell Attorney
Richard Hale Attorney
Todd Ericson Attorney
Matthew Corker Attorney
Daniel Iracki Attorney
Julia Miller Attorney
David Milton Attorney
Charles Sorenson Attorneys for Plaintiffs
Thomas Edwards Attorney
Raymond Roebuck Attorney
Angelo Patacca Attorneys for Plaintiffs
Bruce Anderson Attorneys for Plaintiffs
James Gustafson Attorneys for Plaintiffs
John Mills Attorneys for Defendants
Courtney Brewer Attorneys for Defendants
John DeVault Attorneys for Defendants
David Woods Attorneys for Defendants
George Tsougarakis Attorneys for Defendants
Charles Cohen Attorneys for Defendants
Julissa Rodriguez Attorney
Michael Clarke Attorneys for Plaintiffs
Andrew McDonald Attorney
Bob Freemon Attorney
David Barnhill Attorney
Gary Miller Attorney
Michael Moran Attorney
William Corley Attorney
Christopher Carlyle Attorney
Laurie Adams Attorney
Stephen Charpentier Attorney
Sammy Cacciatore Attorney
Adam Morrison Attorney
Stephen Orchard Attorney
Kimberly Simoes Attorney
Kurt Alexander Attorney
Calvin Brown Attorney
John Hamilton Attorney
Charles Steinberg Attorney
Jennifer Mansfield Attorney
Richard Kolodinsky Attorney
Ty Tyler Attorney
Jonathan Hall Attorney
David Alpizar Attorney
Douglas Beam Attorney
James Rinaman Attorney
Kimberly Driggers Attorney
Dean Leboeuf Attorney
Matthew Schultz Attorneys for Defendants
Karen Curtis Attorneys for Defendants
David Sales Attorney
Stephanie Eady Attorneys for Defendants
John Walker Attorneys for Defendants
John Yarber Attorneys for Defendants
Kelly Luther Attorney
William Latham Attorney
Margarita Ruiz Attorney
Randal Baringer Attorney
Daniel Drake Attorneys for Defendants
William Hudson Attorney
Charles Barrett Attorney
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Filing # 124720017 E-Filed 04/12/2021 11:06:58 AM IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT, IN AND FOR PINELLAS COUNTY, FLORIDA SMALL CLAIMS DIVISION Case No. 20-006863-SC RIDGE TOP EXTERIORS LLC A FLORIDA LIMITED LIABILITY COMPANY, Plaintiff, V. ELISABETH PARKER and MATT S. TURPIN, Defendants. i DEFENDANTS' MOTION TO CONTINUE Defendants, through undersigned counsel, motion this Court for an order continuing the April 15, 2021, court hearing, set on Plaintiffs Proposed Final Judgment, Plaintiffs Affidavit of Attorney's Fees and Costs and Affidavit of Disinterested Attorney as to Plaintiffs Attorneys' Fees and Costs, and in support, states as follows: FACTUAL BACKGROUND 1. On March 30,2021, this Court issued a Judgment in favor of the Plaintifffor Counts I, Iland Ill. 2. A hearing was scheduled for the Plaintiffs Proposed Final Judgment, Plaintiff's Affidavit of Attorney's Fees and Costs and Affidavit of Disinterested Attorney as to Plaintiffs Attorneys' Fees and Costs on April 15,2021. 3. As of April 9, 2021, Defendants hired undersigned counsel to represent them for the upcoming hearing. 4. Undersigned counsel is requesting a continuance to review the billing entries, evaluate whether the Defendants need an expert witness (which is likely considering the amount of money requested), time to obtain that expert, and time to prepare for the hearing. 5. Defendants are requesting this continuance in good faith. Page 1 of 3 ***ELECTRONICALLYFILED 04/12/2021 11:06:58 AM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** 6. A denial of the continuance would create an injustice for the Defendants as the counsel hired to represent them would be unable to effectively prepare for the hearing and Defendants would be unable to obtain their own expert (if it is determined that one is needed) prior to the hearing. See Garner v. Langford, 55 So. 3d 711 (Fla. 1 st DCA 2011 ). Defendants are seeking to have fair and adequate presentation to assist in their case. See Baron v. Baron, 941 So. 2d 1233 (Fla. 2d DCA 2006). 7. The Court provided Defendants two weeks to prepare for the hearing, and Defendants diligently sought counsel to assist them. Defendants were unaware that they had an option to obtain their own expert. Additionally, Defendants were unaware that undersigned counsel would need additional time to prepare for hearing when seeking the representation. See /d. 8. Plaintiff will not be prejudice by the continuance. Plaintiff may suffer a slight inconvenience, but that inconvenience is not outweighed by the injustice and prejudice that Defendants would suffer without the continuance. See /d. 9. Undersigned counsel contacted Plaintiffs counsel regarding the request for continuance. Plaintiffs counsel objected as the expert they hired is available to testify on the date set by the court. Respectfully submitted April 12,2021. RHODUS LAW FIRM, PLLC /s/ Kristin Rhodus, Esq. Kristin M. Rhodus, Esq. Florida Bar No. 88792 447 3rd Ave N, Ste. 406 St. Petersburg, Florida 33701 Telephone: (727) 954-3720 Facsimile: (727) 493-5500 Attorney for Defendants Page 2 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoing was served by Electronic Emai on Counsel of Record through the Florida Courts E-Filing Portal on the 12th day of Apri 2021 to: Sean P. Cox, Esq. Cox Law, PLLC 156 E Bloomingdale Ave. Brandon, FL 33511-8179 Telephone: (813) 685-8600 sean@coxlawplc.com Attorney for Plaintiff RHODUS LAW FIRM, PLLC /s/ Kristin Rhodus, Esq. Kristin M. Rhodus, Esq. Florida Bar No. 88792 447 3rd Ave N, Ste. 406 St. Petersburg, Florida 33701 Telephone: (727) 954-3720 Facsimile: (727) 493-5500 Attorney for Defendants Page 3 of 3