On April 09, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Para, Jeffrey James,
and
Richardson, Dawna,
Smith, Betty,
for AUTO NEGLIGENCE
in the District Court of Flagler County.
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Filing # 138681931 E-Filed 11/17/2021 09:47:26 AM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN
AND FOR FLAGLER COUNTY, FLORIDA
JEFFREY PARA, CASE NO: 2021CA187
Plaintiff,
vs.
BETTY SMITH AND DAWNA
RICHARDSON,
Defendants.
/
MOTION TO EXTEND TIME FOR SERVICE OF PROCESS
COMES NOW the Plaintiff, JEFFREY PARA, by and through the undersigned attorneys,
pursuant to Florida Rules of Civil Procedure 1.070(j), and upon this showing of good cause,
requests an extension of time through and including March 17, 2022, within which to serve the
initial process and initial pleadings upon Defendant, BETTY SMITH AND DAWNA
RICHARDSON, and would show to this Court the basis for this request and good cause contained
herein as follows:
1. Due to an excusable and inadvertent calendaring error, the Plaintiff failed to serve the
Defendants within 120 days pursuant to the Rules of Civil Procedure.
2. The undersigned worked with all dispatch after discovering the error, and will now attempt
service at the last known address of Defendants, BETTY SMITH AND DAWNA
RICHARDSON.
3. Attempts to complete service are continuing and hopefully can be completed within the
requested extension of time.
4. This motion is being made in good faith, and not for purposes of delay.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 11/18/2021 11:50 AMWHEREFORE, Plaintiffs, JEFFREY PARA, respectfully requests entry of an order
extending the time of service of process through and including March 17, 2022.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on November 17, 2021, I electronically filed the foregoing
with the Clerk of the Courts by using the Florida Courts eFiling Portal.
bi anabrio
Sidney Sanabria, Esquire
FBN 1018167
Morgan & Morgan, P.A.
198 Broadway
Kissimmee, FL 34741
Telephone: (407) 452-6980
Facsimile: (407) 572-0118
Primary email: ssanabria@forthepeople.com
Secondary email:
hmercadocolon@forthepeople.com
Attorney for Plaintiff
Document Filed Date
November 17, 2021
Case Filing Date
April 09, 2021
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Filing # 138681931 E-Filed 11/17/2021 09:47:26 AM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, FLORIDA JEFFREY PARA, CASE NO: 2021CA187 Plaintiff, vs. BETTY SMITH AND DAWNA RICHARDSON, Defendants. / MOTION TO EXTEND TIME FOR SERVICE OF PROCESS COMES NOW the Plaintiff, JEFFREY PARA, by and through the undersigned attorneys, pursuant to Florida Rules of Civil Procedure 1.070(j), and upon this showing of good cause, requests an extension of time through and including March 17, 2022, within which to serve the initial process and initial pleadings upon Defendant, BETTY SMITH AND DAWNA RICHARDSON, and would show to this Court the basis for this request and good cause contained herein as follows: 1. Due to an excusable and inadvertent calendaring error, the Plaintiff failed to serve the Defendants within 120 days pursuant to the Rules of Civil Procedure. 2. The undersigned worked with all dispatch after discovering the error, and will now attempt service at the last known address of Defendants, BETTY SMITH AND DAWNA RICHARDSON. 3. Attempts to complete service are continuing and hopefully can be completed within the requested extension of time. 4. This motion is being made in good faith, and not for purposes of delay. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 11/18/2021 11:50 AMWHEREFORE, Plaintiffs, JEFFREY PARA, respectfully requests entry of an order extending the time of service of process through and including March 17, 2022. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on November 17, 2021, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal. bi anabrio Sidney Sanabria, Esquire FBN 1018167 Morgan & Morgan, P.A. 198 Broadway Kissimmee, FL 34741 Telephone: (407) 452-6980 Facsimile: (407) 572-0118 Primary email: ssanabria@forthepeople.com Secondary email: hmercadocolon@forthepeople.com Attorney for Plaintiff