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UNITED STATES DISTRICT COURT FOR THE

SOUTHERN DISTRICT OF FLORIDA

West Palm Beach Division

BRITTANY ROBERSON, REBECCA 

FREEMAN, BIANCA VIÑAS, TIFFANY 

KING, and TRESHA THOMPSON, 

individually and on behalf of others similarly 

situated,

 Plaintiffs, 

v.

HEALTH CAREER INSTITUTE LLC (dba 

HCI COLLEGE LLC and HCI 

ACQUISITION LLC), FLORIAN 

EDUCATION INVESTORS LLC, and 

STEVEN W. HART,

 Defendants.

Civil Action No. 9:22-cv-81883-RAR

PLAINTIFFS’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

MOTION TO COMPEL BETTER AND MORE COMPLETE INTERROGATORY

RESPONSES FROM DEFENDANT HEALTH CAREER INSTITUTE LLC

Pursuant to Local Rule 7.1, Plaintiffs Brittany Roberson, Rebecca Freeman, Bianca Viñas, 

Tiffany King, and Tresha Thompson (collectively, “Plaintiffs”) hereby file this Unopposed Motion 

for Extension of Time to File Motion to Compel Better and More Complete Interrogatory

Responses from Defendant Health Career Institute LLC (dba HCI College LLC and HCI 

Acquisition LLC) (“HCI”).

1. Plaintiffs served their first set of interrogatories on HCI on April 20, 2023. 

Responses were due on May 22, 2023, but HCI sought, and Plaintiffs granted, an extension until 

May 26.

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2. On June 9, 2023, counsel for the Parties conferred by phone. Undersigned counsel 

raised several issues with HCI’s interrogatory responses, including HCI’s objection that certain 

interrogatories were vague or ambiguous. Counsel agreed that undersigned counsel would send a 

formal discovery letter after Plaintiffs’ depositions, which were scheduled to occur the following 

week.

3. At the close of depositions, Defendants’ counsel stipulated to an extension until 

July 3 for Plaintiffs to file a motion to compel better and more complete interrogatory responses, 

pursuant to Local Rule 26.1(g)(1).

4. On June 26, 2023, undersigned counsel sent Defendants’ counsel a detailed letter 

describing specific deficiencies in HCI’s interrogatory responses, providing further explanation of 

certain terms of art, and requesting better and more complete responses, and asked for a telephonic 

conference to discuss the contents of the letter as soon as possible. On June 29, 2023, Defendants’ 

counsel proposed a call the following afternoon.

5. At the June 30 conference, Defendants’ counsel stated that, because they had been 

diligently working to comply with the deadline for HCI’s responses to Plaintiffs’ second request 

for production, they had not had the opportunity to carefully review the discovery letter or to begin 

preparing supplemental discovery responses. Counsel for the parties agreed to reconvene on July 

7, 2023, to determine whether any disputes remain to be resolved and to discuss a timeline for 

supplemental responses.

6. Plaintiffs request an extension of 18 days, until July 21, 2023, to file a motion to 

compel, if necessary, based on any deficiencies that may remain after HCI has supplemented its 

responses. 

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7. Good cause exists to extend the deadline. The Parties have been working 

cooperatively to manage the discovery process. The requested extension will allow Plaintiffs 

adequate time to review and determine whether the forthcoming supplemental responses are 

sufficient and will obviate the need for potentially unnecessary discovery motions.

8. The requested extension is not for the purpose of delay and will not prejudice the 

Parties.

WHEREFORE, Plaintiffs respectfully asks this Court to grant their Unopposed Motion for 

Extension of Time and enter an Order permitting Plaintiffs an extension of 18 days, until July 21, 

to file a motion to compel as to any remaining deficient discovery responses. 

Certificate of Good Faith Conference

Pursuant to Local Rule 7.1(a)(3)(A), I hereby certify that counsel for the movant has 

conferred with counsel for Defendants, who stated they did not oppose this motion.

Dated: June 30, 2023

Respectfully submitted,

/s/ Nicole Mayer

NICOLE MAYER 

Florida Bar No. 012035

Nicole@MayerLawFlorida.com

171 Dommerich Drive

Maitland, Florida 32751

(352) 494-3657

REBECCA EISENBREY (pro hac vice)

reisenbrey@ppsl.org

VICTORIA ROYTENBERG (pro hac vice)

vroytenberg@ppsl.org

Project on Predatory Student Lending

769 Centre Street, Suite 166

Jamaica Plain, MA 02130

(617) 322-2808

Counsel for Plaintiffs

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