`
`IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
`
`IN AND FOR BROWARD COUNTY, FLORIDA
`
`SIERRA SNOWHITE KINIBRELL, Individually
`and as Personal Representative of the Estate of
`Stuart Howard Snowhite, Decedent,
`
`CIVIL DIVISION
`
`CASE NO. CACE 17-018461
`
`Plaintiff,
`
`DIVISION: BOWMAN
`
`vs.
`
`JENNY BIANCA, MARIA C. ROMERO,
`and THE TACO SPOT, CORP.,
`
`Defendants.
`
`/
`
`MOTION FOR EXTENSION OF TIME TO DEPOSE DIANE C. FLORES
`
`COME NOW, Defendants, Jenny Bianca and Maria C. Romero,
`
`(hereinafter the
`
`“Defendants”) by and through their undersigned attorney and file this their Motion for Extension
`
`of Time to Depose Diane C. Flores and in support thereof state, as follows:
`
`1.
`
`On August 26, 2019, the Court entered an Order on Motion for Leave to Substitute
`
`Handwriting Expert. A copy of said Order is attached hereto as Exhibit “A” and incorporated
`
`herein by reference.
`
`2.
`
`The referenced inspection was performed by Diane C. Flores (the substituted expert)
`
`on November 1, 2019.
`
`3.
`
`The 60 day time period in the Order expires on November 4, 2019. Proposed dates
`
`for the deposition of Ms. Flores have been circulated, but a date has not yet been set.
`
`4.
`
`Defendants request an extension of time to depose Ms. Flores on a date and time
`
`agreeable to counsel, taking into consideration their respective schedules and the schedule of Ms.
`
`- 1 -
`
`MARK R. MANCERI, P.A.O 1600 South Federal Highway 0 Suite 900 O Pompano Beach, FL 33062 O (954) 491-7099
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/01/2019 04:11:37 PM.****
`
`
`
`CASE NO. CACE 17-018461
`
`Flores.
`
`5.
`
`This matter is not currently noticed or set for trial.
`
`WHEREFORE, Defendants, Defendants, Jenny Bianca and Maria C. Romero request that
`
`this Court grant their Motion for Extension of Time to Depose Diane Flores, award them
`
`attorney’s fees and costs and grant them such other relief the Court deems just, equitable and
`
`proper.
`
`MARK R. MANCERI, P.A.
`
`Attorney for Defendants
`1600 South Federal Highway, Suite 900
`Pompano Beach, Florida 33062
`Telephone: (954) 491-7099
`E-mail: mrmlaw@comcast.net
`
`mrmlaw1@gmail.com
`
`By/:,
`
`L fl‘m&
`” Mark R. Manceri, Esq.
`Florida Bar No. 444560
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
`
`e-mail to the designated address(es) to all parties on the following Service List, this 151 day of
`
`November, 2019.
`
`Q
`
`,
`
`\CO/Rq'
`
`ark R. Manceri, Esq.
`
`MARK R. MANCERI, RAJ 1600 South Federal Highway 0 Suite 900 O Pompano Beach, FL 33062 O (954) 491-7099
`
`-2-
`
`
`
`CASE NO. CACE 17-018461
`
`SERVICE LIST
`
`Daniel L. McDermott, Esq.
`Adrian Philip Thomas, P.A.
`Las Olas Square, Suite 1050
`515 E. Last Olas Blvd.
`
`Fort Lauderdale, Florida 33301
`
`dmcdermott@aptpa.com
`lalvarez@aptpa.com
`legal-service@aptpa.com
`
`Alexander P. Gil, Esq.
`Adrian Philip Thomas, PA.
`Las Olas Square, Suite 1050
`515 E. Last Olas Blvd.
`
`Fort Lauderdale, Florida 33301
`
`agil@aptpa.com
`apil@aptpa.com
`legal-service@aptpa.com
`
`Roger Slade, Esq.
`Haber Slade, P.A.
`251 NW 23rd Street
`
`Miami, Florida 33127
`
`rslade@haber.law
`
`rcasamayor@haber.law
`cpla@haber.law
`dbhpaservice@haber.law
`
`MARK R. MANCERI, P.A.O 1600 South Federal Highway 0 Suite 900 O Pompano Beach, FL 33062 0 (954) 491-7099
`
`-3-
`
`
`
`
`
`10/23/2019
`
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`I IN THE CIRCIIIT COURT: FOR-THE 171',H JUDICIAL CIRCUIT
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`PersonalRepresentatlveofthe'Estate ofSIuart Howard
`CASE NC: CACE 17-018461
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`CIVIL DIVISION02
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`hups://mail ,googlc.com/mail/u/OMinbox/thlKJVZsXnKchZIannhMPbrSWlezNFJLmCPXgnGFmgannDCjMszJKMle’kaSBGflprojccto:l
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