Motion,Ex Parte: RIDGE TOP EXTERIORS LLC Vs. MATT S TURPIN, ELISABETH PARKER

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                                Filing #     121841382 E-Filed 02/22/2021                03:54:07 PM

                                 IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
                                IN AND FOR PINELLAS COUNTY, FLORIDA                            -

                                                                                                  CIVIL DIVISION

                RIDGE TOP EXTERIORS, LLC,                                                        Case No.:         2020-006863-SC
                a Florida limited liability company,                                             Division:
                         Plaintiff
                V



                MATT     S. TURPIN, and
                ELISABETH PARKER,
                         Defendants.                         i


                                        PLAINTIFF'S MOTION TO CONDUCT DISCOVERY


                         Plaintiff,  RIDGE TOP        EXTERIORS,        LLC,    by  and   through   the  undersigned     counsel, and

                Pursuant to    Rule   7.020   of the   Florida   Small   Claims    Rules,   hereby   files this  Motion to     Conduct


                Discovery and in support thereof would aver as follows:

                          1.      This is  an  action for breach of contact and foreclosure of lien due to the Defendant's


                failure to pay for services rendered and        product delivered that improved real property            owned   by the

                Defendants.


                         2.       Defendants, MATT         S. TURPIN and ELIZABETH PARKER appeared pro-se for Pre-


                Trial on December 15,2020 and requested that the Court continue the Pre-Trialto                   a later date in order


                for Defendants to retain counsel. Subsequently,           a new   Pre-Trial was scheduled for       January 12,    2021


                beginning at    1.00 pm.


                         3        On January     11,2020, the day before the Pre- Trial, a Notice ofAppearance ofCounsel

                was   filed by Wm. Newt Hudson,         Esq.,on behalf ofthe Defendants.

                         4.       At the rescheduled Pre-Trial       on  January 12,2021      Defendants MATT S. TURPIN and


                ELIZABETH PARKER              appeared with     Mr.  Hudson     as their counsel and he raised various defenses


                to the  allegations plead by Plaintiff in the Complaint.

                         5.       Conveniently, after      Defendants' counsel       was  notified of Plaintiff's intent to     further


                discovery the     defenses   raised   and  after Defendant's      were   served with    the  Plaintiff' s Request    for


                Admissions,     counsel for Defendantswithdrew from representationof the Defendantsin this matter.




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    ***ELECTRONICALLYFILED 02/22/2021              03:54:07 PM:   KEN  BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
                         6.       Plaintiffwould    dr
                                                     request that the Court allow Plaintiffto conduct         discovery to refute the

                Defendants' defenses raised at the        January 12,2021      Pre-Trial Conference and to address the various


                defensesraised at the pre-trialfor the first time.


                         WHEREFORE, Plaintiff RIDGE                 TOP    EXTERIORS,        LLC    requests that this    Court allow


               Plaintiffto conduct     discovery regarding the defensesraised by the Defendants at Pre-Trial and for such

               other and further relief this Honorable Court deems appropriate under the circumstances.




                                                         CERTIFICATE OF SERVICE


                         I HEREBY CERTIFY that a true and correct copy ofthe                    foregoing has been furnished by e-
                designation on this 22nd day of February2021 to:                                                       and via regular
                U.S. Mail to Pro Se DefendantsMATT              S. TUPRIN and ELISABETHPARKER at                    119 South Spring
                Blvd.,     Tarpon      Springs,     FL    34689      and     via    E-mail     to                                    and




                                                                                        Cox Law, PLLC


                                                                                        By: /s/  SG.Pl-
                                                                                        Sean P. Cox, Esq.
                                                                                        Florida Bar Number 706760
                                                                                        156 E. Bloomindale Ave.
                                                                                        Brandon, FL 33511-8179
                                                                                        Tel: 813-685-8600
                                                                                        Fax:  813-685-8699
                SPC/vag                                                                 sean
                                                                                              @coxlawplc.com
                Cc: Client                                                              vanessa   @coxlawplc.com
                                                                                        Attorney for Plaintiff




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