On August 24, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Christine Demello,
and
Lesley Oneal,
Richard A Oneal Jr,
for CA - Auto Negligence
in the District Court of Orange County.
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Filing # 64330646 E-Filed 11/17/2017 10:05:18 AM
IN THE CIRCUIT COURT OF THE
9TH JUDICIAL CIRCUIT IN AND
FOR ORANGE COUNTY, FLORIDA
CHRISTINE DEMELLO, Case No.: 2017-CA-007822-O
Plaintiff,
vs.
RICHARD A. O'NEAL, JR. AND
LESLEY O'NEAL,
Defendant.
_____________________________/
MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
DISCOVERY
COMES NOW the Defendants, RICHARD A. O'NEAL, JR. AND
LESLEY O'NEAL, by and through the undersigned counsel and files this their
Motion for Enlargement of Time to Respond to Discovery and as grounds
therefore would state as follows:
1. The Plaintiff, CHRISTINE DEMELLO, has propounded a set of
Interrogatories, Request for Admissions and Request for Production upon this
Defendant with the Summons and Complaint.
2. Defendants, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL,
were served with said discovery on October 9, 2017.
3. Defendant, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL,
would request additional time to adequately respond to said discovery.
4. This Motion for Enlargement of Time is not dilatory in nature, and
there will be no prejudice to the Plaintiff in the granting of this motion.
5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend
the time within which to respond to Plaintiff’s outstanding discovery.
6. The Defendants reserves their right to object to any of Plaintiff’s
discovery based upon work product, attorney-client or other applicable privilege,
protection or immunity from discovery and specifically reserves their right to
subsequently raise same.
WHEREFORE, Defendants, RICHARD A. O'NEAL, JR. AND LESLEY
O'NEAL, respectfully requests this Honorable Court grant this Motion for
Extension of Time to Respond to Discovery for the reasons set forth above.
Page 2 of 3
Case No. 2017-CA-007822-O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
th
furnished by E-Mail this 17 day of November 2017 to:
W. Doug Martin, Esq.
Morgan & Morgan, P.A.
20 N. Orange Ave., Ste. 1600
PO Box 4979
Orlando, FL 32801-4624 at
dmartin@forthepeople.com
mgesualdi@forthepeople.com
ROIG LAWYERS
7380 Sand Lake Road, Suite 600
Orlando, FL 32819
(407) 480-4952 / (954) 462-7798 Fax
Pleadings@RoigLawyers.com
BY: /s/ Scharome R.Wolfe
SCHAROME R. WOLFE, ESQ.
Florida Bar No. 672947
/jmo
Page 3 of 3
Case No. 2017-CA-007822-O
Document Filed Date
November 17, 2017
Case Filing Date
August 24, 2017
Category
CA - Auto Negligence
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Filing # 64330646 E-Filed 11/17/2017 10:05:18 AM IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CHRISTINE DEMELLO, Case No.: 2017-CA-007822-O Plaintiff, vs. RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, Defendant. _____________________________/ MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY COMES NOW the Defendants, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, by and through the undersigned counsel and files this their Motion for Enlargement of Time to Respond to Discovery and as grounds therefore would state as follows: 1. The Plaintiff, CHRISTINE DEMELLO, has propounded a set of Interrogatories, Request for Admissions and Request for Production upon this Defendant with the Summons and Complaint. 2. Defendants, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, were served with said discovery on October 9, 2017. 3. Defendant, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, would request additional time to adequately respond to said discovery. 4. This Motion for Enlargement of Time is not dilatory in nature, and there will be no prejudice to the Plaintiff in the granting of this motion. 5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time within which to respond to Plaintiff’s outstanding discovery. 6. The Defendants reserves their right to object to any of Plaintiff’s discovery based upon work product, attorney-client or other applicable privilege, protection or immunity from discovery and specifically reserves their right to subsequently raise same. WHEREFORE, Defendants, RICHARD A. O'NEAL, JR. AND LESLEY O'NEAL, respectfully requests this Honorable Court grant this Motion for Extension of Time to Respond to Discovery for the reasons set forth above. Page 2 of 3 Case No. 2017-CA-007822-O CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been th furnished by E-Mail this 17 day of November 2017 to: W. Doug Martin, Esq. Morgan & Morgan, P.A. 20 N. Orange Ave., Ste. 1600 PO Box 4979 Orlando, FL 32801-4624 at dmartin@forthepeople.com mgesualdi@forthepeople.com ROIG LAWYERS 7380 Sand Lake Road, Suite 600 Orlando, FL 32819 (407) 480-4952 / (954) 462-7798 Fax Pleadings@RoigLawyers.com BY: /s/ Scharome R.Wolfe SCHAROME R. WOLFE, ESQ. Florida Bar No. 672947 /jmo Page 3 of 3 Case No. 2017-CA-007822-O