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Filing # 101564430 E-Filed 01/13/2020 03:28:48 PM
IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT, IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No.: 502019CA007584XXXXMB
RONALD ANTONIEWICZ,
Plaintiff,
v.
LVI INTERMEDIATE HOLDINGS, INC.,
A Delaware Corporation.
Defendant.
/
JOINT MOTION TO CONTINUE TRIAL DATE
AND AMEND SCHEDULING ORDER
Plaintiff, Ronald Antoniewicz, and Defendant, LVI Intermediate Holdings, Inc.
(collectively “Parties”), hereby move, pursuant to Fla. R. Civ. P. 1.460, to continue the trial date
to the Court’s June jury trial docket and to amend the associated pretrial deadlines to correspond
with the new trial date. In support of the motion, the Parties state as follows:
1, This matter is currently set for trial on the Court’s jury trial calendar beginning
March 16, 2020.
2. The Parties have entered into a brief stand-still agreement ending March 31, 2020
while Defendant continues to work toward achieving a reorganization of its financial and business
operations as a result of extreme financial hardship. During the stand-still period, the parties will
strive to resolve all issues between them thereby avoiding the need for further litigation.
3. At present, it is imperative for Defendant to conserve its limited resources as it
continues to work with third parties on its reorganization. To conserve resources and to avoid the
potentially unnecessary burden and expense of litigation, the parties have agreed to and move for
*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 01/13/2020 03:28:48 PM ***Antoniewicz v. LVI Intermediate Holdings, Inc.
Case No. 502019CA007584XXXXMB
Joint Motion to Continue Trial Date and Amend Scheduling Order
a continuance of the trial to the Court’s June jury trial calendar and modification of the associated
pretrial schedule.
4. For the reasons discussed above, the current pretrial schedule does not provide
sufficient time for the parties to complete discovery, attend mediation, and then to prepare for trial
in a manner that will allow the parties to focus their efforts on resolving the case while conserving
their limited resources and to permit Defendant the additional time it needs to turn around its
financial and business operations through reorganization.
5. The parties will not be prejudiced by a continuance of the trial to the Court’s June
jury trial calendar. To the contrary, it is in the parties’ best interests not to expend their limited
and valuable resources preparing for trial at this time.
6. Undersigned counsel has conferred with counsel for Plaintiff regarding the
requested continuance of the trial and pretrial deadlines and counsel for Plaintiff agrees with and
joins in the relief requested.
7. The parties request this brief continuance in good faith and not for purposes of
delay. This is the first trial setting for this case. The parties have not previously requested a
continuance of the trial.
For the reasons set forth above, the parties move for a brief continuance of the trial to the
Court’s June 2020 jury trial calendar and corresponding modification of the pretrial scheduling
order to allow sufficient time for Defendant to achieve financial and operational reorganization
and, thereafter, to complete discovery, to participate in mediation, and to prepare for trial should
the parties not resolve the Plaintiff's claims.
/s/ Robyn S. Hankins /s/ Merry E. Lindberg
Robyn S. Hankins, Esq. Merry E. Lindberg, Esq.
FL Bar No. 0008699 FL Bar No. 308102
Telephone: 561-721-3890 Telephone: (561) 345-7505Antoniewicz v. LVI Intermediate Holdings, Inc.
Case No. 502019CA007584XXXXMB
Joint Motion to Continue Trial Date and Amend Scheduling Order
Email: robyn@hankins-law.com Email: mlindberg@fordharrison.com
Robyn S. Hankins, P.L. David M. Gobeo, Esq.
4600 Military Trl., Suite 217 FL Bar No. 0016565
Jupiter, FL 33458 Telephone: (561) 345-7512
Facsimile: 561-721-3889 Email: dgobeo@fordharrison.com
FORD & HARRISON LLP
Attorneys for Plaintiff 1450 Centrepark Blvd., Suite 325
West Palm Beach, FL 33401
Facsimile: (561) 345-7501
Attorneys for Defendant
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on January 13, 2020, I electronically filed with the Clerk of
Court, using the Florida filing portal, which will send notice of electronic filing to: Robyn S.
Hankins, Robyn S. Hankins, P.L., (Robyn@hankins-law.com), 4600 Military Trail, Suite 217,
Jupiter, FL 33458.
/s/ Merry E. Lindber;
Merry E. Lindberg, Esq.
FL Bar No. 308102
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Filing # 101564430 E-Filed 01/13/2020 03:28:48 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No.: 502019CA007584XXXXMB RONALD ANTONIEWICZ, Plaintiff, v. LVI INTERMEDIATE HOLDINGS, INC., A Delaware Corporation. Defendant. / JOINT MOTION TO CONTINUE TRIAL DATE AND AMEND SCHEDULING ORDER Plaintiff, Ronald Antoniewicz, and Defendant, LVI Intermediate Holdings, Inc. (collectively “Parties”), hereby move, pursuant to Fla. R. Civ. P. 1.460, to continue the trial date to the Court’s June jury trial docket and to amend the associated pretrial deadlines to correspond with the new trial date. In support of the motion, the Parties state as follows: 1, This matter is currently set for trial on the Court’s jury trial calendar beginning March 16, 2020. 2. The Parties have entered into a brief stand-still agreement ending March 31, 2020 while Defendant continues to work toward achieving a reorganization of its financial and business operations as a result of extreme financial hardship. During the stand-still period, the parties will strive to resolve all issues between them thereby avoiding the need for further litigation. 3. At present, it is imperative for Defendant to conserve its limited resources as it continues to work with third parties on its reorganization. To conserve resources and to avoid the potentially unnecessary burden and expense of litigation, the parties have agreed to and move for *** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 01/13/2020 03:28:48 PM ***Antoniewicz v. LVI Intermediate Holdings, Inc. Case No. 502019CA007584XXXXMB Joint Motion to Continue Trial Date and Amend Scheduling Order a continuance of the trial to the Court’s June jury trial calendar and modification of the associated pretrial schedule. 4. For the reasons discussed above, the current pretrial schedule does not provide sufficient time for the parties to complete discovery, attend mediation, and then to prepare for trial in a manner that will allow the parties to focus their efforts on resolving the case while conserving their limited resources and to permit Defendant the additional time it needs to turn around its financial and business operations through reorganization. 5. The parties will not be prejudiced by a continuance of the trial to the Court’s June jury trial calendar. To the contrary, it is in the parties’ best interests not to expend their limited and valuable resources preparing for trial at this time. 6. Undersigned counsel has conferred with counsel for Plaintiff regarding the requested continuance of the trial and pretrial deadlines and counsel for Plaintiff agrees with and joins in the relief requested. 7. The parties request this brief continuance in good faith and not for purposes of delay. This is the first trial setting for this case. The parties have not previously requested a continuance of the trial. For the reasons set forth above, the parties move for a brief continuance of the trial to the Court’s June 2020 jury trial calendar and corresponding modification of the pretrial scheduling order to allow sufficient time for Defendant to achieve financial and operational reorganization and, thereafter, to complete discovery, to participate in mediation, and to prepare for trial should the parties not resolve the Plaintiff's claims. /s/ Robyn S. Hankins /s/ Merry E. Lindberg Robyn S. Hankins, Esq. Merry E. Lindberg, Esq. FL Bar No. 0008699 FL Bar No. 308102 Telephone: 561-721-3890 Telephone: (561) 345-7505Antoniewicz v. LVI Intermediate Holdings, Inc. Case No. 502019CA007584XXXXMB Joint Motion to Continue Trial Date and Amend Scheduling Order Email: robyn@hankins-law.com Email: mlindberg@fordharrison.com Robyn S. Hankins, P.L. David M. Gobeo, Esq. 4600 Military Trl., Suite 217 FL Bar No. 0016565 Jupiter, FL 33458 Telephone: (561) 345-7512 Facsimile: 561-721-3889 Email: dgobeo@fordharrison.com FORD & HARRISON LLP Attorneys for Plaintiff 1450 Centrepark Blvd., Suite 325 West Palm Beach, FL 33401 Facsimile: (561) 345-7501 Attorneys for Defendant CERTIFICATE OF SERVICE I HEREBY CERTIFY that on January 13, 2020, I electronically filed with the Clerk of Court, using the Florida filing portal, which will send notice of electronic filing to: Robyn S. Hankins, Robyn S. Hankins, P.L., (Robyn@hankins-law.com), 4600 Military Trail, Suite 217, Jupiter, FL 33458. /s/ Merry E. Lindber; Merry E. Lindberg, Esq. FL Bar No. 308102