On July 13, 2017 a
Party Discovery
was filed
involving a dispute between
Galway Bay Mobile Homeowners Association, Inc.,
and
Biza Corp. D B A Galway Bay Mobile Home Park,
for Other - Matters not falling within the other Civil Subcatego
in the District Court of Monroe County.
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Filing # 126823247 E-Filed 05/14/2021 11:17:13 AM
IN THE CIRCUIT COURT IN AND FOR MONROE COUNTY, FLORIDA
GALWAY BAY MOBILE HOMEOWNERS
ASSOCIATION, INC., GENERAL JURISDICTION DIVISION
Plaintiff, CASE NO.: 17- CA-00166-M
vs.
BIZA, CORP, d/b/a GALWAY BAY MOBILE
HOME PARK,
Defendant.
_________________________________________/
UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S
FIRST SET OF EXPERT INTERROGATORIES AND DEFENDANT’S FIRST EXPERT
REQUEST FOR PRODUCTION OF DOCUMENTS
Plaintiff, GALWAY BAY MOBILE HOMEOWNER’S ASSOCIATION, INC. (“Plaintiff
HOA”), serves this Motion for Extension of Time to Respond to Defendant’s First Set of Expert
Interrogatories and Defendant’s First Expert Request for Production of Documents and in support
states:
1. Defendant filed Defendant’s First Set of Expert Interrogatories and Request for
Production on April 13, 2021.
2. The deadline to respond to the above discovery requests is May 13, 2021.
3. Plaintiff is requesting a three-week extension of the deadline for discovery.
4. Plaintiff needs additional time to gather information and documents that are
responsive to Defendant’s First Set of Expert Interrogatories and Defendant’s First
Expert Request for Production of Documents and in support states:
5. Plaintiff does not oppose this request.
5/14/2021 11:17 AM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1
6. Plaintiff will not be prejudiced by granting this request for an extension of time, and
the interests of justice will be served.
WHEREFORE, Plaintiff respectfully requests that this court grant Plaintiff’s Motion for
Extension of Time to Respond to Defendant’s First Set of Expert Interrogatories and Defendant’s
First Expert Request for Production of Documents until June 3, 2021.
Respectfully submitted,
LEGAL SERVICES OF GREATER MIAMI, INC.
By: /s/ Davalyn Suarez
Davalyn Suarez, Esq.
Florida Bar No. 1015563
Attorney for Plaintiff
4343 West Flagler Street, Suite 100
Miami, Florida 33134
Telephone: (305) 438-2552
Facsimile: (305) 438-2552
E-mail: dsuarez@legalservicesmiami.org
Secondary: pleadings@legalservicesmiami.org
Secondary: crodriguez@legalservicesmiami.org
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Notice of
Electronic Filing on May 13, 2021, to Brett Lieberman Esq., Attorneys for Plaintiff at
brett@elrolaw.com.
By: /s/ Davalyn Suarez
Davalyn Suarez, Esq.
Florida Bar No. 1015563
Page 2 of 2
5/14/2021 11:17 AM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2
Document Filed Date
May 14, 2021
Case Filing Date
July 13, 2017
Category
Other - Matters not falling within the other Civil Subcatego
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Filing # 126823247 E-Filed 05/14/2021 11:17:13 AM IN THE CIRCUIT COURT IN AND FOR MONROE COUNTY, FLORIDA GALWAY BAY MOBILE HOMEOWNERS ASSOCIATION, INC., GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: 17- CA-00166-M vs. BIZA, CORP, d/b/a GALWAY BAY MOBILE HOME PARK, Defendant. _________________________________________/ UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S FIRST SET OF EXPERT INTERROGATORIES AND DEFENDANT’S FIRST EXPERT REQUEST FOR PRODUCTION OF DOCUMENTS Plaintiff, GALWAY BAY MOBILE HOMEOWNER’S ASSOCIATION, INC. (“Plaintiff HOA”), serves this Motion for Extension of Time to Respond to Defendant’s First Set of Expert Interrogatories and Defendant’s First Expert Request for Production of Documents and in support states: 1. Defendant filed Defendant’s First Set of Expert Interrogatories and Request for Production on April 13, 2021. 2. The deadline to respond to the above discovery requests is May 13, 2021. 3. Plaintiff is requesting a three-week extension of the deadline for discovery. 4. Plaintiff needs additional time to gather information and documents that are responsive to Defendant’s First Set of Expert Interrogatories and Defendant’s First Expert Request for Production of Documents and in support states: 5. Plaintiff does not oppose this request. 5/14/2021 11:17 AM eFiled - Kevin Madok, CPA, Clerk of the Court Page 1 6. Plaintiff will not be prejudiced by granting this request for an extension of time, and the interests of justice will be served. WHEREFORE, Plaintiff respectfully requests that this court grant Plaintiff’s Motion for Extension of Time to Respond to Defendant’s First Set of Expert Interrogatories and Defendant’s First Expert Request for Production of Documents until June 3, 2021. Respectfully submitted, LEGAL SERVICES OF GREATER MIAMI, INC. By: /s/ Davalyn Suarez Davalyn Suarez, Esq. Florida Bar No. 1015563 Attorney for Plaintiff 4343 West Flagler Street, Suite 100 Miami, Florida 33134 Telephone: (305) 438-2552 Facsimile: (305) 438-2552 E-mail: dsuarez@legalservicesmiami.org Secondary: pleadings@legalservicesmiami.org Secondary: crodriguez@legalservicesmiami.org CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Notice of Electronic Filing on May 13, 2021, to Brett Lieberman Esq., Attorneys for Plaintiff at brett@elrolaw.com. By: /s/ Davalyn Suarez Davalyn Suarez, Esq. Florida Bar No. 1015563 Page 2 of 2 5/14/2021 11:17 AM eFiled - Kevin Madok, CPA, Clerk of the Court Page 2