On May 31, 1982 a
Motion,Ex Parte
was filed
involving a dispute between
Elevation Development Ii Llc,
and
Bronson, David A,
Bronson Family Limited Partnership,
Bronson, Linda A,
for CIRCUIT CIVIL
in the District Court of Osceola County.
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Filing # 145975468 E-Filed 03/18/2022 10:51:10 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
ELEVATION DEVELOPMENT II, LLC, Case No. 2021-CA-001956
a Florida limited liability company,
Plaintiff,
v.
BRONSON FAMILY LIMITED
PARTNERSHIP, a Nevada limited
partnership,
Defendant.
/
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME FOR PLAINTIFF TO
RESPOND TO DEFENDANT’S COUNTER-CLAIM
Plaintiff, ELEVATION DEVELOPMENT II, LLC (“Elevation Development”), by and
through its undersigned counsel, hereby moves for an enlargement of time to respond to
Defendant, BRONSON FAMILY LIMITED PARTNERSHIP’s (“Defendant”), Counter-Claim,
and in support thereof states as follows:
1. Plaintiff served their initial Complaint on Defendant on August 5, 2021.
2. Defendant filed with the Court a Notice of Appearance on August 5, 2021.
3. On September 14, 2021, Defendant filed and served Answers and Affirmative
Defenses.
4. On January 24, 2022, Plaintiff filed with the Court a Motion for Leave to File Amended
Complaint.
5. The Court granted Plaintiff’s Motion for Leave to File Amended Complaint on
February 4, 2022.
6. Defendant filed and served Answers and Affirmative Defenses to Plaintiff’s First
Amended Complaint and Counter-Claim on February 28, 2022.
7. Plaintiff’s deadline to respond to Defendant’s Counter-claim is currently due on March
21, 2022.
8. Plaintiff requests a thirty (30) day extension of time to file its response to Defendant’s
Counter-Claim.
9. Defendant is unopposed to this Enlargement of Time.
WHEREFORE, Plaintiff ELEVATION DEVELOPMENT II, LLC, respectfully request
that this Court enter an Order granting a thirty (30) day extension of time to file its response to
Defendant’s Counter-Claim, and for such other relief this Court deems just and proper.
Dated: March 18, 2022. Respectfully submitted,
/s/ Patrick J. Hennessey, Jr.
PATRICK J. HENNESSEY, JR., ESQ.
Florida Bar No.: 0106964
Email 1: patrick.hennessey@gmlaw.com
Email 2: eric.cruz@gmlaw.com
EDMUND O. LOOS III, ESQ.
Florida Bar No. 899161
Email 1: edmund.loos@gmlaw.com
Email 2: tami.austin@gmlaw.com
GREENSPOON MARDER LLP
201 East Pine Street, Suite 500
Orlando, FL 32801
Telephone: 407-425-6559
Facsimile: 407-422-6583
CHAD J. TAMAROFF, ESQ.
Florida Bar No. 163368
Email 1: chad.tamaroff@gmlaw.com
Email 2: agatha.mctier@gmlaw.com
GREENSPOON MARDER LLP
200 E. Broward Blvd., Suite 1800
Ft. Lauderdale, FL 33301
Telephone: 954-491-1120
Facsimile: 954-343-6950
Counsel for Plaintiff ELEVATION
DEVELOPMENT II, LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 18, 2022, I electronically filed the foregoing
document with the Clerk of Court by using the Florida Court’s E-Filing Portal, which then will
serve a true and correct copy of the foregoing document to all counsel of record.
/s/ Patrick J. Hennessey, Jr.
Patrick J. Hennessey, Jr., Esq.
Document Filed Date
March 18, 2022
Case Filing Date
May 31, 1982
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Filing # 145975468 E-Filed 03/18/2022 10:51:10 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA ELEVATION DEVELOPMENT II, LLC, Case No. 2021-CA-001956 a Florida limited liability company, Plaintiff, v. BRONSON FAMILY LIMITED PARTNERSHIP, a Nevada limited partnership, Defendant. / UNOPPOSED MOTION FOR ENLARGEMENT OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANT’S COUNTER-CLAIM Plaintiff, ELEVATION DEVELOPMENT II, LLC (“Elevation Development”), by and through its undersigned counsel, hereby moves for an enlargement of time to respond to Defendant, BRONSON FAMILY LIMITED PARTNERSHIP’s (“Defendant”), Counter-Claim, and in support thereof states as follows: 1. Plaintiff served their initial Complaint on Defendant on August 5, 2021. 2. Defendant filed with the Court a Notice of Appearance on August 5, 2021. 3. On September 14, 2021, Defendant filed and served Answers and Affirmative Defenses. 4. On January 24, 2022, Plaintiff filed with the Court a Motion for Leave to File Amended Complaint. 5. The Court granted Plaintiff’s Motion for Leave to File Amended Complaint on February 4, 2022. 6. Defendant filed and served Answers and Affirmative Defenses to Plaintiff’s First Amended Complaint and Counter-Claim on February 28, 2022. 7. Plaintiff’s deadline to respond to Defendant’s Counter-claim is currently due on March 21, 2022. 8. Plaintiff requests a thirty (30) day extension of time to file its response to Defendant’s Counter-Claim. 9. Defendant is unopposed to this Enlargement of Time. WHEREFORE, Plaintiff ELEVATION DEVELOPMENT II, LLC, respectfully request that this Court enter an Order granting a thirty (30) day extension of time to file its response to Defendant’s Counter-Claim, and for such other relief this Court deems just and proper. Dated: March 18, 2022. Respectfully submitted, /s/ Patrick J. Hennessey, Jr. PATRICK J. HENNESSEY, JR., ESQ. Florida Bar No.: 0106964 Email 1: patrick.hennessey@gmlaw.com Email 2: eric.cruz@gmlaw.com EDMUND O. LOOS III, ESQ. Florida Bar No. 899161 Email 1: edmund.loos@gmlaw.com Email 2: tami.austin@gmlaw.com GREENSPOON MARDER LLP 201 East Pine Street, Suite 500 Orlando, FL 32801 Telephone: 407-425-6559 Facsimile: 407-422-6583 CHAD J. TAMAROFF, ESQ. Florida Bar No. 163368 Email 1: chad.tamaroff@gmlaw.com Email 2: agatha.mctier@gmlaw.com GREENSPOON MARDER LLP 200 E. Broward Blvd., Suite 1800 Ft. Lauderdale, FL 33301 Telephone: 954-491-1120 Facsimile: 954-343-6950 Counsel for Plaintiff ELEVATION DEVELOPMENT II, LLC CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 18, 2022, I electronically filed the foregoing document with the Clerk of Court by using the Florida Court’s E-Filing Portal, which then will serve a true and correct copy of the foregoing document to all counsel of record. /s/ Patrick J. Hennessey, Jr. Patrick J. Hennessey, Jr., Esq.