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Filing # 89016477 E-Filed 05/06/2019 10:54:01 AM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
ELIZABETH L. BALZARANO, individually
and as Personal Representative of the Estate
of MICHELLE L. BALZARANO,
Plaintiff, GENERAL JURISDICTION DIVISION
Vv CASE NO. 50-2018-CA-015763-XXXX-MB
LIFELINE RECOVERY, LLC, d/b/a
LIFELINE RECOVERY SUPPORT
SERVICES, a Foreign Corporation; JOHN
BROGAN; LIFE CHANGES ADDICTION
TREATMENT CENTER OF THE PALM
BEACHES; and WARBIRD PROPERTIS,
LLC, d/b/a CAMERON VILLA, LLC, a
Florida Corporation,
Defendants.
/
DEFENDANTS’ MOTION FOR EXTENSION OF TIME
Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a LIFELINE
RECOVERY SUPPORT SERVICES (“Defendants”) move for an extension of time to respond
to the Complaint filed by Plaintiff ELIZABETH L. BALZARANO, individually and as Personal
Representative of the Estate of MICHELLE L. BALZARANO (“Plaintiff”) and states:
1 Undersigned counsel just became involved in this case and needs an enlargement
of time to become familiar with all of the facts, fully analyze the allegations in the Complaint, and
prepare an appropriate response to this action.
2. Based on the foregoing, Defendants respectfully request an extension of time up to
and including May 15, 2019, to respond to the Complaint.
3 This enlargement of time is not being sought purposes of delay.
-1-
FARRELL | PATEL | JOMARRON | LOPEZ
ATTORNEYS AT LAW
FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/06/2019 10:54:01 AM
4 Defendants are unaware of any reason why Plaintiff would be prejudiced by this
enlargement of time.
WHEREFORE, Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a
LIFELINE RECOVERY SUPPORT SERVICES respectfully request this Honorable Court grant
this motion for an extension of time and order the response to the Complaint to be due by May 15,
2019, and for such further relief this Court deems just and proper under the circumstances.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy hereof via email on this 6" day of
May, 2019, upon: Thomas Graham, Esq., and Thomas D. Graham, Esq., Leesfield Scolaro, P.A.,
colaro@leesfield.com; graham@leesfield.com; Jonathan M. Midwall, Esq., and Alyssa M.
Tomberg, Esq., Cole, Scott & Kissane, PA, jonathan.midwall@csklegal.com,
alyssa.tornberg@csklegal.com, lorraine.mata@csklegal.com.
FARRELL | PATEL | JOMARRON | LOPEZ
Counsel for Brogan and Lifeline Recovery, LLC
4300 Biscayne Boulevard, Suite 305
Miami, Florida 33137
Telephone: (305) 717-7530
Facsimile: (305) 717-7539
Primary e-mail: eservice@justice360.com
Secondary e-mail: jjomarron@justice360.com
Secondary e-mail: wmccaughan@justice360.com
By: __/s/ William P. McCaughan, Jr.
Jesmany Jomarron, Esq.
Florida Bar No. 69165
William P. McCaughan, Jr., Esq.
Florida Bar No.: 41573
WPM/afy
1452.001
-2-
FARRELL | PATEL | JOMARRON | LOPEZ
ATTORNEYS AT LAW
Preview
Filing # 89016477 E-Filed 05/06/2019 10:54:01 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA ELIZABETH L. BALZARANO, individually and as Personal Representative of the Estate of MICHELLE L. BALZARANO, Plaintiff, GENERAL JURISDICTION DIVISION Vv CASE NO. 50-2018-CA-015763-XXXX-MB LIFELINE RECOVERY, LLC, d/b/a LIFELINE RECOVERY SUPPORT SERVICES, a Foreign Corporation; JOHN BROGAN; LIFE CHANGES ADDICTION TREATMENT CENTER OF THE PALM BEACHES; and WARBIRD PROPERTIS, LLC, d/b/a CAMERON VILLA, LLC, a Florida Corporation, Defendants. / DEFENDANTS’ MOTION FOR EXTENSION OF TIME Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a LIFELINE RECOVERY SUPPORT SERVICES (“Defendants”) move for an extension of time to respond to the Complaint filed by Plaintiff ELIZABETH L. BALZARANO, individually and as Personal Representative of the Estate of MICHELLE L. BALZARANO (“Plaintiff”) and states: 1 Undersigned counsel just became involved in this case and needs an enlargement of time to become familiar with all of the facts, fully analyze the allegations in the Complaint, and prepare an appropriate response to this action. 2. Based on the foregoing, Defendants respectfully request an extension of time up to and including May 15, 2019, to respond to the Complaint. 3 This enlargement of time is not being sought purposes of delay. -1- FARRELL | PATEL | JOMARRON | LOPEZ ATTORNEYS AT LAW FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/06/2019 10:54:01 AM 4 Defendants are unaware of any reason why Plaintiff would be prejudiced by this enlargement of time. WHEREFORE, Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a LIFELINE RECOVERY SUPPORT SERVICES respectfully request this Honorable Court grant this motion for an extension of time and order the response to the Complaint to be due by May 15, 2019, and for such further relief this Court deems just and proper under the circumstances. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy hereof via email on this 6" day of May, 2019, upon: Thomas Graham, Esq., and Thomas D. Graham, Esq., Leesfield Scolaro, P.A., colaro@leesfield.com; graham@leesfield.com; Jonathan M. Midwall, Esq., and Alyssa M. Tomberg, Esq., Cole, Scott & Kissane, PA, jonathan.midwall@csklegal.com, alyssa.tornberg@csklegal.com, lorraine.mata@csklegal.com. FARRELL | PATEL | JOMARRON | LOPEZ Counsel for Brogan and Lifeline Recovery, LLC 4300 Biscayne Boulevard, Suite 305 Miami, Florida 33137 Telephone: (305) 717-7530 Facsimile: (305) 717-7539 Primary e-mail: eservice@justice360.com Secondary e-mail: jjomarron@justice360.com Secondary e-mail: wmccaughan@justice360.com By: __/s/ William P. McCaughan, Jr. Jesmany Jomarron, Esq. Florida Bar No. 69165 William P. McCaughan, Jr., Esq. Florida Bar No.: 41573 WPM/afy 1452.001 -2- FARRELL | PATEL | JOMARRON | LOPEZ ATTORNEYS AT LAW