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Filing # 69080477 E-Filed 03/09/2018 04:54:49 PM
IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT
IN AND FOR MONROE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
GALWAY BAY MOBILE HOMEOWNERS CASE NO.: 2017-CA-000166 MR
ASSOCIATION, INC.,
Plaintiff,
vs.
BIZA, CORP, d/b/a GALWAY BAY MOBILE
HOME PARK,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO PRODUCE DOCUMENTS
RESPONSIVE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION
Defendant, BIZA, CORP. d/b/a GALWAY BAY MOBILE HOME PARK, by and
through its undersigned counsel, hereby files this motion for extension of time within which
to provide its documents responsive to Plaintiff’s First Request for Production, paragraphs
1 through 9, and states:
1. The Court entered its Order on February 21, 2018, directing Defendant to
serve documents responsive to Plaintiff’s First Request for Production, paragraphs 1
through 9 on or before March 9, 2018.
2. Due to damages to the documents stored at Galway Bay caused by flood
waters due to Hurricane Irma, intervening events subsequent to the hurricane that have
affected this business and the inability of the limited staff in the office to compile the
documents requested, 45 days additional time is needed to respond to the discovery.
3. Counsel has communicated with Plaintiff’s counsel via telephone, to
determine if there is any objection to this Motion. Counsel has not returned a telephone
call, at the time of this filing, to advise whether or not there is an objection to the request
for the extension of time.
WHEREFORE, Defendant requests this Court grant its motion to extend the
deadline for filing its responses an additional 45 days to April 23, 2018.
Respectfully submitted, this 9th day of March, 2018.
/s/ David D. Eastman
DAVID D. EASTMAN (FBN 454559)
eastman@floridahousinglaw.com
CAROL S. GRONDZIK (FBN 0156833)
csgrondzik@floridahousinglaw.com
gayledcason@floridahousinglaw.com
Lutz, Bobo & Telfair, P.A.
2155 Delta Blvd. Suite 210-B
Tallahassee, FL 32303
(850) 521-0890 telephone
(850) 521-0891 facsimile
Attorneys for Defendant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished electronically via the Florida e-filing portal to Nejla Calvo, Esq., and Jeffrey M.
Hearne, Esq., Attorneys for Plaintiff, LEGAL SERVICES OF GREATER MIAMI, INC., 4343
West Flagler Street, Suite 100, Miami, FL 33137 (ncalvo@legalservicesmiami.org;
jhe a rn e@ le ga lse rvice sm ia m i. org; c r o d r i g u e z@ l e g a l s e r vi c e s m i a m i . o r g ;
pleadings@legalservicesmiami.org, and Scott L. Baena, Esq., and Jennifer Junger,
Esq., Attorneys for Plaintiff, Bilzin Sumberg Baena Price & Axelrod, LLP, 1450 Brickell
Ave., Ste. 2300, Miami, FL 33131-3456 (sbaena@bilzin.com; jjunger@bilzin.com;
stapanes@bilzin.com; eservice@bilzin.com) this 9th day of March, 2018.
/s/ David D. Eastman
Attorney
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Filing # 69080477 E-Filed 03/09/2018 04:54:49 PM IN THE CIRCUIT COURT OF THE 16TH JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION GALWAY BAY MOBILE HOMEOWNERS CASE NO.: 2017-CA-000166 MR ASSOCIATION, INC., Plaintiff, vs. BIZA, CORP, d/b/a GALWAY BAY MOBILE HOME PARK, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO PRODUCE DOCUMENTS RESPONSIVE TO PLAINTIFF’S FIRST REQUEST FOR PRODUCTION Defendant, BIZA, CORP. d/b/a GALWAY BAY MOBILE HOME PARK, by and through its undersigned counsel, hereby files this motion for extension of time within which to provide its documents responsive to Plaintiff’s First Request for Production, paragraphs 1 through 9, and states: 1. The Court entered its Order on February 21, 2018, directing Defendant to serve documents responsive to Plaintiff’s First Request for Production, paragraphs 1 through 9 on or before March 9, 2018. 2. Due to damages to the documents stored at Galway Bay caused by flood waters due to Hurricane Irma, intervening events subsequent to the hurricane that have affected this business and the inability of the limited staff in the office to compile the documents requested, 45 days additional time is needed to respond to the discovery. 3. Counsel has communicated with Plaintiff’s counsel via telephone, to determine if there is any objection to this Motion. Counsel has not returned a telephone call, at the time of this filing, to advise whether or not there is an objection to the request for the extension of time. WHEREFORE, Defendant requests this Court grant its motion to extend the deadline for filing its responses an additional 45 days to April 23, 2018. Respectfully submitted, this 9th day of March, 2018. /s/ David D. Eastman DAVID D. EASTMAN (FBN 454559) eastman@floridahousinglaw.com CAROL S. GRONDZIK (FBN 0156833) csgrondzik@floridahousinglaw.com gayledcason@floridahousinglaw.com Lutz, Bobo & Telfair, P.A. 2155 Delta Blvd. Suite 210-B Tallahassee, FL 32303 (850) 521-0890 telephone (850) 521-0891 facsimile Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished electronically via the Florida e-filing portal to Nejla Calvo, Esq., and Jeffrey M. Hearne, Esq., Attorneys for Plaintiff, LEGAL SERVICES OF GREATER MIAMI, INC., 4343 West Flagler Street, Suite 100, Miami, FL 33137 (ncalvo@legalservicesmiami.org; jhe a rn e@ le ga lse rvice sm ia m i. org; c r o d r i g u e z@ l e g a l s e r vi c e s m i a m i . o r g ; pleadings@legalservicesmiami.org, and Scott L. Baena, Esq., and Jennifer Junger, Esq., Attorneys for Plaintiff, Bilzin Sumberg Baena Price & Axelrod, LLP, 1450 Brickell Ave., Ste. 2300, Miami, FL 33131-3456 (sbaena@bilzin.com; jjunger@bilzin.com; stapanes@bilzin.com; eservice@bilzin.com) this 9th day of March, 2018. /s/ David D. Eastman Attorney