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Filing # 89347313 E-Filed 05/10/2019 05:21:23 PM
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
v. CASE NO. 50-2018-CA-015763-XXXX-MB
LIFELINE RECOVERY, LLC, d/b/a
LIFELINE RECOVERY SUPPORT
SERVICES, a Foreign Corporation; JOHN
BROG. IFE CHANGES ADDICTION
TREATMENT CENTER OF THE PALM
BEACHES; and WARBIRD PROPERTIS,
LLC, d/b/a CAMERON VILLA, LLC, a
Florida Corporation,
Defendants.
DEFENDANTS’ SECOND MOTION FOR EXTENSION OF TIME
Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a LIFELINE
RECOVERY SUPPORT SERVICES (“Defendants”) move for a second extension of time to
tespond 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 recently became involved in this case.
2. The Court previously granted an extension until May 15, 2019 to respond to
plaintiffs complaint.
3. Defendants request a second extension of time to respond to Plaintiff's complaint
to become familiar with all of the facts, fully analyze the allegations in the Complaint, and prepare
an appropriate response to this action.
pee
FARRELL | PATEL | JOMARRON | LOPEZ
ATTORNEYS AT LAW
CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAFY FLEDY AgMAINNAA NE-94-92 DAA
PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yur tue ig U2 1.20 VE4. A second extension would also allow the Parties more time to engage in early
nattlamant nanntintiana
Sctuciment negouauons.
5. Based on the foregoing, Defendants respectfully request a second extension of time
up to and including June 4, 2019, to respond to the Complaint.
6. This enlargement of time is not being sought purposes of delay.
7. 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
RECOVERY SUPPORT SERV!
this second motion for an extension of time and order the response to the Complaint to be due by
June 4, 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 10'" day of
May, 2019, upon: Thomas Graham, Esq., and Thomas D. Graham, Esq., Leesfield Scolaro, P.A.,
scolaro@leesfield.com; graham@leesfield.com; Jonathan M. Midwall, Esq., and Alyssa M.
Tomberg, Esq., Cole, Scott & Kissane, P.A., jonathan.midwall@csklegal.com,
alyssa.tornberg@csklegal.com, lorraine.mata@ecsklegal.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
Drimaru email: acarvina/Ainctina%AN cam
aiunaty CAulaik, Cer VICK] UOUCe I OV.CUnE
Secondary e-mail: jiomarron@justice360.com
Secondary e-mail: wmecaughan@justice360.com
By: __/s/ William P. McCaughan, Jr.
Jesmany Jomarron, Esq.
Florida Bar No. 69165
William P_McCanghan, Ir_ Esa.
Florida Bar No.: 41573
Hae
FARRELL | PATEL | JOMARRON | LOPEZ
ATTORNEYS AT LAW
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Filing # 89347313 E-Filed 05/10/2019 05:21:23 PM 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 v. CASE NO. 50-2018-CA-015763-XXXX-MB LIFELINE RECOVERY, LLC, d/b/a LIFELINE RECOVERY SUPPORT SERVICES, a Foreign Corporation; JOHN BROG. IFE CHANGES ADDICTION TREATMENT CENTER OF THE PALM BEACHES; and WARBIRD PROPERTIS, LLC, d/b/a CAMERON VILLA, LLC, a Florida Corporation, Defendants. DEFENDANTS’ SECOND MOTION FOR EXTENSION OF TIME Defendants JOHN BROGAN and LIFELINE RECOVERY, LLC, d/b/a LIFELINE RECOVERY SUPPORT SERVICES (“Defendants”) move for a second extension of time to tespond 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 recently became involved in this case. 2. The Court previously granted an extension until May 15, 2019 to respond to plaintiffs complaint. 3. Defendants request a second extension of time to respond to Plaintiff's complaint to become familiar with all of the facts, fully analyze the allegations in the Complaint, and prepare an appropriate response to this action. pee FARRELL | PATEL | JOMARRON | LOPEZ ATTORNEYS AT LAW CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAFY FLEDY AgMAINNAA NE-94-92 DAA PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yur tue ig U2 1.20 VE4. A second extension would also allow the Parties more time to engage in early nattlamant nanntintiana Sctuciment negouauons. 5. Based on the foregoing, Defendants respectfully request a second extension of time up to and including June 4, 2019, to respond to the Complaint. 6. This enlargement of time is not being sought purposes of delay. 7. 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 RECOVERY SUPPORT SERV! this second motion for an extension of time and order the response to the Complaint to be due by June 4, 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 10'" day of May, 2019, upon: Thomas Graham, Esq., and Thomas D. Graham, Esq., Leesfield Scolaro, P.A., scolaro@leesfield.com; graham@leesfield.com; Jonathan M. Midwall, Esq., and Alyssa M. Tomberg, Esq., Cole, Scott & Kissane, P.A., jonathan.midwall@csklegal.com, alyssa.tornberg@csklegal.com, lorraine.mata@ecsklegal.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 Drimaru email: acarvina/Ainctina%AN cam aiunaty CAulaik, Cer VICK] UOUCe I OV.CUnE Secondary e-mail: jiomarron@justice360.com Secondary e-mail: wmecaughan@justice360.com By: __/s/ William P. McCaughan, Jr. Jesmany Jomarron, Esq. Florida Bar No. 69165 William P_McCanghan, Ir_ Esa. Florida Bar No.: 41573 Hae FARRELL | PATEL | JOMARRON | LOPEZ ATTORNEYS AT LAW