Stipulation,Agreement: Galway Bay Mobile Homeowners Association, Inc. vs BIZA Corp. d/b/a Galway Bay Mobile Home Park

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 136835376 E-Filed 10/19/2021 01:25:06 PM



                                IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT
                                               IN AND FOR MONROE COUNTY, FLORIDA

                                                                                GENERAL JURISDICTION DIVISION
                 GALWAY BAY MOBILE HOMEOWNERS                                   CASE NO.: 17-CA-000166-MR
                 ASSOCIATION, INC.,

                                   Plaintiff,
                 vs.

                 BIZA, CORP, d/b/a GALWAY BAY MOBILE
                 HOME PARK,

                                   Defendant.
                                                                        /

                  AGREED MOTION TO EXTEND TIME TO RESPOND AND OBJECT TO PLAINTIFF’S
                    FIRST EXPERT REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT

                          Defendant, BIZA, CORP, d/b/a GALWAY BAY MOBILE HOME PARK (“Defendant”), by

                 and  through    undersigned     counsel,   hereby   files this  Agreed    Motion   Seeking    Extension    of Time   to

                 Respond and Object to Plaintiff’s First Expert Request for Production of Documents to Defendant

                 (the “Motion”), and respectfully states as follows:

                                                             REQUESTED RELIEF

                          1.       On   September     19,   2021,   Plaintiff,  GALWAY         BAY    MOBILE       HOMEOWNERS

                 ASSOCIATION, INC. (“Plaintiff”), filed and served Plaintiff’s First Expert Request for Production

                 of Documents to Defendant (the “Expert Discovery Requests”).

                          2.       The   current  deadline    for Defendant     to Respond     or Object   to  the Expert   Discovery

                 Requests is October 19, 2021.

                          3.       The Expert Discovery Requests inquire into matters that require complete access to

                 the Defendant’s expert’s documents and records.

                          4.       Defendant requires an additional thirty (30) days to Respond and Object to the Expert

                 Discovery Requests.




                                10/19/2021 1:25 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1
                          5.       Defendant respectfully requests an additional thirty (30) days, through and including

                 November 18, 2021, to respond to the Expert Discovery Requests.

                          6.       This  is Defendant’s     first motion   for  extension   of  time  to  respond   and  object   to the

                 Expert Discovery Requests. The relief requested herein is not intended to cause delay, and the request

                 is being made in good faith.

                          7.       Prior   to filing   this Motion,     Defendant’s     counsel    communicated       with   Plaintiff’s

                 counsel regarding the extension to respond and object to the Expert Discovery Requests. Plaintiff’s

                 counsel   advised   that  Plaintiff  agrees  to  the 30-day    extension   of  time  to  respond   and  object   to the

                 Expert Discovery Requests sought herein.

                          WHEREFORE, Defendant respectfully requests the entry of an order granting the instant

                 Motion,    extending   the  deadline   to  respond   and  object   to the  Expert   Discovery    Requests    through

                 and including November 18, 2021, and for such other and further relief that is just and proper.

                                                                       Respectfully submitted,

                                                                       EDELBOIM LIEBERMAN REVAH PLLC
                                                                       Counsel for Defendant
                                                                       20200 W. Dixie Hwy., Ste 905
                                                                       Miami, FL 33180
                                                                       Telephone: (305) 928-1070
                                                                       Facsimile: (305) 928-1114
                                                                       Email: brett@elrolaw.com

                                                                       By: /s/ Brett D. Lieberman
                                                                       Brett D. Lieberman (FBN 69583)
                                                                       Lance Kaufman (FBN 1022126)




                                                                            2


                                10/19/2021 1:25 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2
                                                         CERTIFICATE OF SERVICE

                          I HEREBY CERTIFY that a true and correct copy of the foregoing was submitted through

                 the Florida E-Portal on October 19, 2021 and served on all parties authorized to receive notifications

                 via the Florida E-Portal generated service email, including Plaintiff’s counsel, Davalyn Suarez, Esq,

                 at dsuarez@legalservicesmiami.org.

                                                                                  By: /s/ Brett D. Lieberman
                                                                                       Brett D. Lieberman




                                                                            3


                                10/19/2021 1:25 PM eFiled - Kevin Madok, CPA, Clerk of the Court Page 3