Filing# 135887689 E-Filed 10/04/2021 10:14:46 PM

IN THE CIRCUIT COURT OF THE 15TH

WDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA

FIRST AMERICAN BANK, as successor CASE No.: 502016-CA-009292

By merger to Bank of Coral Gables, LLC,

Plaintiff,

V.

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LAURENCE S. SCHNEIDER,
STEPHANIE L. SCHNEIDER, et al.

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Defendant(s).

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DEFENDANT'S MOTION FOR EXTENSION OF TIME

COMES NOW the Defendant STEPHANIE L. SCHNEIDER (hereinafter "Defendant" and/or

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"Ms. Schneider"), by and through the undersigned counsel and pursuant to Fla. R. Civ. P. 1.090,
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and hereby files this Motion for Extension of Time to, and in support thereof states:

1. The Defendant's response to Plaintiff's Discovery, pursuant to this Court's Order dated
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September 23, 2021 [D.E. 660] is due today, Tuesday, October 5, 2021.
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2. Defendant's Counsel is in the midst of a multi-day family court trial in Miami-Dade County
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Circuit Court and had to prepare last week for two other significant trials which settled or were

continued on the verge of trial.

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3. Florida Rule of Civil Procedure 1.090 provides in pertinent part:

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(B) Enlargement. When an act is required or allowed to be done at or within a

specified time by order of the court, by these rules, or by notice given thereunder, for

cause shown the court at any time in its discretion (1) with or without notice, may order

the period enlarged if request thereof is made before the expiration of the period

originally prescribed or as extended by a previous order.

FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 10/04/2021 10: 14:46 PM
 Fla. R. Civ. P. 1.090 (2002).

4. This motion is made timely before the deadline to file a Responses to Plaintiff's Discovery [D.E.

638].

5. This motion is made in good faith and will not cause prejudice to the Plaintiff.

6. The Defendant request an additional ten (10) days to file a Responses to Plaintiff's Discovery.

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WHEREFORE, the Defendant respectfully request that this Honorable Court grants this

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Motion for Extension of Time, as well as award any additional relief that is just and equitable in light of

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the foregoing.

CERTIFICATE OF SERVICE
ED
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I CERTIFY that a copy hereof has been furnished on October 5, 2021, to John W. Keller, Esq.
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jkeller@kellermesa.com and Sheyla Mesa, Esq. smesa@kellermesa.com, at KELLER & MESA,

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LLP, 121 Majorca Avenue, #200, Coral Gables, FL 33134, and to all other Parties Designated to Receive

Service of Court Documents via Florida's eFiling Portal pertaining to this case.
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Respectfully Submitted,
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MCCARTHY & YERSEL, PLLC

Attorneys for the Defendant
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4929 SW 74th Court, Ste. 5

Miami, FL 33155
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Ph.: (305) 407-8006 I Fax.: (866) 676-4671

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By: Isl Martin G. McCarthy

Martin G. McCarthy, Esq. Florida Bar No.: 149896
Service Email: mccarthy@myattorneyservices.com
Emre Yersel, Esq., Florida Bar No.: 114485
Service Email: eyersel@myattorneyservices.com

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