Request,Application: BUZZARD BEACH INC vs RICCIARDI, SUZANNE

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                                Filing # 137193716 E-Filed 10/25/2021 01:35:07 PM



                                IN THE CIRCUIT COURT, FIFTH JUDICIAL CIRCUIT
                                      IN AND FOR LAKE COUNTY, FLORIDA

            BUZZARD BEACH, INC.,                                    CASE NO.: 35-2021-CA-001554-AXXX-XX
            a Florida for profit corporation, and                   DIVISION: CIVIL
            JACK PROTZMAN,                                          JUDGE: JAMES R. BAXLEY

                              Plaintiffs,

            Vv.


            SUZANNE RICCIARDI,

                              Defendant.
                                                              /

                                  DEFENDANT SUZANNE RICCIARDI’?S OBJECTION
                                    TO PLAINTIFFS’ REQUEST FOR EXTENSION

                       Defendant Suzanne Ricciardi files this objection in response to Plaintiffs’ Motion for

            Extension and as grounds opposing Plaintiffs’ motion provides:

                       1      Plaintiffs have frivolously and carelessly filed a wrongful lis pendens to harass and

            delay Defendant Suzanne Ricciardi from selling her property.

                       2      Defendant     Ricciardi requested   an emergency     hearing   to discharge   Plaintiffs’

            wrongful and frivolous lis pendens and the Court provided hearing time for evidentiary hearing on

            October 26, 2021.

                       3      Plaintiffs now seek an extension to further delay the evidentiary hearing on the

            discharge of Plaintiffs wrongful lis pendens on the sole basis that Defendant Ricciardi filed notice

            of her intent to request judicial notice at the evidentiary hearing.

                       4      Defendant Ricciardi’s notice of intent to request judicial notice at an evidentiary

            hearing is not grounds for an extension of time.

                       5      Plaintiffs provide no legal authority whatsoever for their request for an extension

            of time.




FILED: LAKE COUNTY, GARY J. COONEY, CLERK,                  10/25/2021 03:00:55 PM.
6       Plaintiffs’ request for an extension is frivolous, interposed for solely for harassment

and continued delay, and is a disservice to the administration of justice in discharging Plaintiffs’

wrongful lis pendens and should be denied.

                                           CONCLUSION

        WHEREFORE        for the reasons set forth above, Defendant Suzanne Ricciardi requests

that the Court enter an order denying Plaintiffs’ motion for an extension of time and hear this

matter at the evidentiary hearing set for October 26, 2021 at the Court earliest convenience

between 1:30pm and 3:30pm on Defendant’s Emergency Motion to Discharge Lis Pendens

and Motion to Dismiss.

        Dated October 25, 2021.

/s/Michael G. Moore
Michael G. Moore, Esq.
Fla. Bar No. 934909
Moore Lex, P.A.
206 Wellisford Way
DeLand, FL 32724
(386) 232-8451
michael@moorelex.com
Counsel for Defendant Suzanne Ricciardi.


                                  CERTIFICATE OF SERVICE

        THEREBY CERTIFY that on October 25, 2021, the foregoing was electronically filed with

the Clerk of Court using the Florida Courts efiling portal which will automatically send a copy to

all counsel of record in this case registered to receive service, including:

David G. Hamilton, Esq.:
davidghamiltonpllc@gmail.com,
dghparalegal@gmail.com,
davidghamiltoniii@gmail.com
Counsel for Plaintiffs
                                                        /s/Michael G. Moore
                                                        Michael G. Moore, Esq