KIM VAUGHAN LERNER LLP 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 1:22-cv-23617-JAL 

MARCIA ENNIS, 

 Plaintiff, 

v. 

GUARD FORCE INTERNATIONAL, INC., 

 Defendant. 

 / 

PLAINTIFF’S RESPONSE TO THE 

COURT’S PAPERLESS ORDER TO SHOW CAUSE 

Pursuant to the Court’s Paperless Order to Show Cause (ECF 5), Plaintiff 

Marcia Ennis files this response. In support of this response, Plaintiff states as 

follows: 

MEMORANDUM OF LAW 

Plaintiff effectuated service of process on November 14, 2022. See ECF 4. 

Within one day of receiving the Verified Return of Service, Plaintiff’s counsel filed 

the Verified Return of Service with the Court. See id. Based on the date of service of 

process, Defendant had until December 5, 2022, to serve a response to the 

Complaint, whether by motion or answer. 

On November 29, 2022, Alyssa Castelli of the law firm Spire Law contacted 

the undersigned indicating that her firm had been retained to represent Defendant 

in this action. See Exhibit 1. Ms. Castelli requested an extension of time for 

Defendant to respond to the Complaint through December 28, 2022. See id. The 

Case 1:22-cv-23617-JAL Document 6 Entered on FLSD Docket 12/06/2022 Page 1 of 3
2 

KIM VAUGHAN LERNER LLP 

undersigned declined the request, but did indicate Plaintiff would not oppose an 

extension through December 16, 2022. See id. Ms. Castelli accepted that extension. 

See id. 

Based on these communications, Plaintiff anticipated that Defendant would 

file the required motion for extension of time with the Court. It was for that reason 

that Plaintiff did not file a motion for default this morning when the deadline to 

respond to the Complaint had expired. Nevertheless, having received the Paperless 

Order to Show Cause, the undersigned did provide a copy to Ms. Castelli and did 

indicate that her law firm file a motion for extension of time. If a motion is not filed 

or should this Court deny the extension and a response not filed, Plaintiff is prepared 

to file a motion for entry of default. But Plaintiff has held off doing so given Plaintiff 

did indicate it would not oppose an extension of time through December 16, 2022. 

Dated: December 6, 2022 Respectfully submitted, 

By: /s/Brian L. Lerner 

Brian L. Lerner (Fla. Bar No. 177202) 

blerner@kvllaw.com 

Kim Vaughan Lerner LLP 

312 SE 17th Street, Suite 300 

Fort Lauderdale, Florida 33316 

Telephone: (954) 527-1115 

Facsimile: (954) 527-1116 

Attorneys for Plaintiff 

Case 1:22-cv-23617-JAL Document 6 Entered on FLSD Docket 12/06/2022 Page 2 of 3
3 

KIM VAUGHAN LERNER LLP 

CERTIFICATE OF SERVICE 

I hereby certify that on December 6, 2022, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF. I also certify that a true and 

correct copy of the foregoing document was served via transmission of Notices of 

Electronic Filing generated by CM/ECF or in some other authorized manner for 

those counsel or parties who are not authorized to receive electronically Notices of 

Electronic Filing on all counsel or parties of record on the Service List below. 

 By: /s/Brian L. Lerner 

SERVICE LIST 

Brian L. Lerner 

blerner@kvllaw.com 

Kim Vaughan Lerner LLP 

312 SE 17th Street, Suite 300 

Fort Lauderdale, Florida 33316 

Telephone: (954) 527-1115 

Facsimile: (954) 527-1116 

Attorneys for Plaintiff 

Via Transmission of Notices of 

Electronic Filing Generated by CM/ECF 

Alyssa Castelli 

alyssa@spirelawfirm.com 

Spire Law 

2572 W State Rd 426 

Suite 2088 

Oviedo, Florida 32765 

Telephone: (407) 494-0135 

Attorneys for Defendant 

Via E-mail 

Case 1:22-cv-23617-JAL Document 6 Entered on FLSD Docket 12/06/2022 Page 3 of 3