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Filing # 138201178 E-Filed 11/09/2021 02:34:46 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVIL DIVISION
FRANCES BARONE & GABRIEL BARONE,
Plaintiffs,
vs. CASE NO. 2017 CA 003882-0
ASHFORD TRS WQ LLC, a foreign limited
liability company d/b/a WORLD QUEST
RESORT a/k/a WORLDQUEST ORLANDO
RESORT, ASHFORD WQ LICENSEE, LLC,
a foreign limited liability company,
ASHFORD TRS CORPORATION, a foreign
profit corporation, WQ HOTEL
MANAGEMENT LLC, a foreign limited
liability company, WORLDQUEST RESORT
CONDOMINIUM ASSOCIATION, INC., a
Florida not for profit corporation
Defendants,
WORLDQUEST RESORT CONDOMINIUM
ASSOCIATION, INC., a Florida not for profit
corporation,
Cross-Plaintiff,
VS.
WQ HOTEL MANAGEMENT LLC,
A foreign limited liability company,
Cross-Defendant.
/
PLAINTIFF’S, MOTION FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT WORLDQUEST RESORT CONDOMINIUM
ASSOCIATION, INC.’S SECOND REQUEST FOR PRODUCTION AND FIRST SET OF
EXPERT INTERROGATORIES
COMES NOW, Plaintiffs, FRANCES BARONE & GABRIEL BARONE, by and through
undersigned counsel and files this, their motion for extension of time and would show:
1 On or about October 8, 2021, Defendant, WORLDQUEST RESORT CONDOMINIUM
ASSOCIATION, INC filed a Second Request to Produce and First Set of Expert
Interrogatories upon the Plaintiffs.
Plaintiffs are in the process of preparing their responses and anticipates more time will be
necessary to fully prepare their response than is allotted under Florida Rule of Civil
Procedure 1.350.
Plaintiffs therefore requests 30 additional days within which to respond to Defendant's
outstanding discovery.
Plaintiff counsel’s office contacted counsel for Defendant and requested the 30 day extension
on November 8, 2021 via email. No response has been received at the time of the filling of
this motion.
No party will be prejudiced by the granting of this extension.
Plaintiff has, and will continue to, attempt to resolve this issue with Defendant prior to
setting this issue for hearing.
WHEREFORE, Plaintiffs, FRANCES BARONE & GABRIEL BARONE, respectfully
requests this Honorable Court grant their motion for extension of time and any other relief this Court
deems just and proper.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing was filed with the Clerk
via the Florida Courts e-Filing Portal and provided via eservice to: William G. Smoak, Esq., and
Carla M. Sabbagh, Esq., Smoak Trial Lawyers, 320 West Kennedy Blvd., 4th Floor, Tampa, FL
33606, Attorneys for Defendants, Ashford TRS WQ LLC, d/b/a World Quest Resort a/k/a
Worldquest Orlando Resort, Ashford WQ Licensee, LLC, Ashford TRS Corporation and WQ Hotel
Management LLC, courtdocuments@smoaktriallawyers.com and csabbagh@smoaktriallawyers.com,
and Brian W. Bennett, Esq. and Brett A. Marlowe, Esq., Bennett Legal Group, P.A., 214 South
Lucerne Circle East, Suite 201, Orlando, FL 32801, Attorneys for Defendant, Worldquest Resort
Condominium Association, Inc., brian@bennettlegalgroup.com, brett(@bennettlegalgroup.com.
bonnie@bennettlegal group.com, jordan@bennettlegalgroup.com,
this 7 day of bert 4021.
ICARD, MERRILL, CULLIS, TIMM,
FUREN & GINSBURG, P.A.
2033 Main Street, Suite 600
Postal Drawer 4195
Sarasota, Florida 34237
(941) 366 $100 Pho
(941) 366/6384
J. MANGANIELLO, II, ESQ.
Fl id ar No, 0052307
hey: for Plaintiffs
manganiello@icardmerrill.con
rgrek(@icardmerrill.com
00581310-1
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Filing # 138201178 E-Filed 11/09/2021 02:34:46 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION FRANCES BARONE & GABRIEL BARONE, Plaintiffs, vs. CASE NO. 2017 CA 003882-0 ASHFORD TRS WQ LLC, a foreign limited liability company d/b/a WORLD QUEST RESORT a/k/a WORLDQUEST ORLANDO RESORT, ASHFORD WQ LICENSEE, LLC, a foreign limited liability company, ASHFORD TRS CORPORATION, a foreign profit corporation, WQ HOTEL MANAGEMENT LLC, a foreign limited liability company, WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation Defendants, WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC., a Florida not for profit corporation, Cross-Plaintiff, VS. WQ HOTEL MANAGEMENT LLC, A foreign limited liability company, Cross-Defendant. / PLAINTIFF’S, MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC.’S SECOND REQUEST FOR PRODUCTION AND FIRST SET OF EXPERT INTERROGATORIES COMES NOW, Plaintiffs, FRANCES BARONE & GABRIEL BARONE, by and through undersigned counsel and files this, their motion for extension of time and would show: 1 On or about October 8, 2021, Defendant, WORLDQUEST RESORT CONDOMINIUM ASSOCIATION, INC filed a Second Request to Produce and First Set of Expert Interrogatories upon the Plaintiffs. Plaintiffs are in the process of preparing their responses and anticipates more time will be necessary to fully prepare their response than is allotted under Florida Rule of Civil Procedure 1.350. Plaintiffs therefore requests 30 additional days within which to respond to Defendant's outstanding discovery. Plaintiff counsel’s office contacted counsel for Defendant and requested the 30 day extension on November 8, 2021 via email. No response has been received at the time of the filling of this motion. No party will be prejudiced by the granting of this extension. Plaintiff has, and will continue to, attempt to resolve this issue with Defendant prior to setting this issue for hearing. WHEREFORE, Plaintiffs, FRANCES BARONE & GABRIEL BARONE, respectfully requests this Honorable Court grant their motion for extension of time and any other relief this Court deems just and proper. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing was filed with the Clerk via the Florida Courts e-Filing Portal and provided via eservice to: William G. Smoak, Esq., and Carla M. Sabbagh, Esq., Smoak Trial Lawyers, 320 West Kennedy Blvd., 4th Floor, Tampa, FL 33606, Attorneys for Defendants, Ashford TRS WQ LLC, d/b/a World Quest Resort a/k/a Worldquest Orlando Resort, Ashford WQ Licensee, LLC, Ashford TRS Corporation and WQ Hotel Management LLC, courtdocuments@smoaktriallawyers.com and csabbagh@smoaktriallawyers.com, and Brian W. Bennett, Esq. and Brett A. Marlowe, Esq., Bennett Legal Group, P.A., 214 South Lucerne Circle East, Suite 201, Orlando, FL 32801, Attorneys for Defendant, Worldquest Resort Condominium Association, Inc., brian@bennettlegalgroup.com, brett(@bennettlegalgroup.com. bonnie@bennettlegal group.com, jordan@bennettlegalgroup.com, this 7 day of bert 4021. ICARD, MERRILL, CULLIS, TIMM, FUREN & GINSBURG, P.A. 2033 Main Street, Suite 600 Postal Drawer 4195 Sarasota, Florida 34237 (941) 366 $100 Pho (941) 366/6384 J. MANGANIELLO, II, ESQ. Fl id ar No, 0052307 hey: for Plaintiffs manganiello@icardmerrill.con rgrek(@icardmerrill.com 00581310-1