IN THE COUNTY COURT
IN AND FOR SEMINOLE COUNTY, FLORIDA
CIVIL DIVISION
IPFS CORPORATION §
Plaintiff, §
§
v. § Case No.: 2020-CC-002569
§
MED-RIDE FLORIDA, LLC, a Florida §
Limited Liability Company §
Defendant. §
NOTICE OF MOTION FOR CLARIFICATION
You are notified that on _______________ (date), at __________ (time), or as soon thereafter as the Defendant can be heard, in Courtroom _____ of the County Court for Seminole County, Florida, at the Civil Division at ____________________________________________ (Address).
The Defendant will bring on for hearing this Motion for Clarification for the reasons stated in the attached Motion.
Respectfully Submitted,
______________________________
Sandra Caria
In her official capacity as President,
Med-Ride Florida, LLC
1540 International Pkwy Ste 2000
Lake Mary, FL 32746
(407) 844-7985
IN THE COUNTY COURT
IN AND FOR SEMINOLE COUNTY, FLORIDA
CIVIL DIVISION
IPFS CORPORATION §
Plaintiff, §
§
v. § Case No.: 2020-CC-002569
§
MED-RIDE FLORIDA, LLC, a Florida §
Limited Liability Company §
Defendant. §
MEMORANDUM IN SUPPORT OF MOTION FOR CLARIFICATION
NOW COMES Med-Ride Florida, LLC, Defendant, and brings this Motion for Clarification before this Honorable Court and hereby avers as follows:
- Defendant filed Motion for Continuance asking for 180 days to obtain proper legal representation on 04/26/2021.
- This Honorable Court granted Defendant’s Motion for Continuance asking for 180 days to obtain proper legal representation on 04/29/2021.
- In the Order dated 05/13/2021, this Court denied Plaintiff’s Motion to Strike Motion for Continuance. However, the Court also stated that Defendant shall have 10 days from the date the Order was signed (05/13/2021) to obtain counsel to represent it in this matter.
- The Court also stated that Defendant’s failure to obtain counsel shall result in an immediate judgment for Plaintiff in regard to Plaintiff’s Motion to Strike Motion for Continuance.
- Defendant is under the impression that it has 180 days to obtain legal counsel to represent it in this matter pursuant to the Order dated 04/29/2021 granting Defendant’s Motion for Continuance asking for 180 days to obtain proper legal representation.
- Defendant is under the belief that this Honorable Court made an honest mistake in stating that Defendant has 10 days from the date of the Order denying Plaintiff’s Motion to Strike Motion for Continuance to obtain legal counsel instead of 180 days.
REASONS WHEREFORE, Defendant respectfully requests this Honorable Court to clarify that Defendant has 180 days from the date of the Order denying Plaintiff’s Motion to Strike Motion for Continuance to obtain legal representation instead of 10 days, in accordance with the Order granting Defendant’s Motion for Continuance.
Respectfully Submitted,
______________________________
Sandra Caria
in her official capacity as President and on behalf of,
Med-Ride Florida, LLC
1540 International Pkwy Ste 2000
Lake Mary, FL 32746
(407) 844-7985
VERIFICATION
I, Sandra Caria, being duly sworn depose and say that I am the President of Med-Ride Florida, LLC, acting on behalf of Med-Ride Florida, LLC, Defendant in the above entitled action, that I have read the foregoing Motion for Clarification and know the contents thereof. That the same is true of my own knowledge except as to those matters and things stated upon information and belief, and as to those things, I believe them to be true.
________________________________________
Sandra Caria,
in her official capacity as President and on behalf of
Med-Ride Florida, LLC
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this ____ day of _______________, 2021.
______________________________
Notary Public
______________________________
(Printed Name of Notary Public)
My Commission Expires: _______________
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document was sent on the _____ day of _______________, 2021 by regular U.S. mail, by facsimile or certified mail, return receipt requested, to the following parties or attorneys of record:
Markowitz, Ringel, Trusty & Hartog, P.A.
Plaintiff’s Attorneys
9130 South Dadeland Boulevard
Two Datran Center, Suite 1800
Miami, Florida 33156-7858
Phone: (305) 670-5000
Fax: (305) 670-5011
Primary Email: commlitservice@mrthlaw.com
Thomas Ringel
Florida Bar No. 220736
Secondary Email: tringel@mrthlaw.com
Respectfully Submitted,
______________________________
Sandra Caria
in her official capacity as President and on behalf of,
Med-Ride Florida, LLC
1540 International Pkwy Ste 2000
Lake Mary, FL 32746
(407) 844-7985
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