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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 RECONSIDERATION OF THE COURT’S 

ORDER [ECF NO. 145] GRANTING PLAINTIFFS’ UNOPPOSED MOTION FOR 

EXTENSION OF TIME [ECF NO. 144] 

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 Reconsideration of Judge McCabe’s December 27, 2023, Paperless Order (ECF No. 145), 

which granted Plaintiffs’ Motion for Extension of Time to File Motion to Compel Better and More 

Complete Discovery Responses (ECF No. 144) but limited the scope of such motion to the 

supplemental production ordered by this Court on October 27, 2023 (ECF No. 133). In support of 

this Motion, Plaintiffs state as follows: 

1. On December 22, 2023, Plaintiffs filed an unopposed motion (ECF No. 144, 

“Motion for Extension”) requesting an extension until January 9, 2024, to file motions to compel 

Case 9:22-cv-81883-RAR Document 147 Entered on FLSD Docket 12/29/2023 Page 1 of 3
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pursuant to Local Rule 26.1(g)(1) as to: (1) Defendant HCI’s supplemental production produced 

pursuant to this Court’s Order No. 133 entered October 27, 2023; (2) Defendant Florian Education 

Investor’s November 22, 2023, and December 1, 2023, Responses to Plaintiffs’ Second Set of 

Requests for Production; and (3) Defendant HCI’s December 1, 2023, Responses to Plaintiffs’ 

Third Set of Requests for Production.

2. The purpose of the Motion for Extension was to allow the parties to further meet 

and confer, and negate, or at least substantially narrow, any motions to compel with respect to the 

outstanding discovery issues.

3. Believing that discovery in this Case had closed, this Court entered a Paperless 

Order on December 27, 2023 (ECF No. 145), granting the Motion for Extension but limiting the 

scope of such motion to Defendant HCI’s supplemental production ordered by the Court on 

October 27, 2023 (ECF No. 133).

4. Plaintiffs respectfully ask that the Court reconsider its order in light of the fact that 

Judge Ruiz entered an order on October 24, 2023 (ECF No. 128), setting a March 29, 2024, 

deadline for the close of all discovery.

5. WHEREFORE, Plaintiffs respectfully asks that this Court reconsider its December 

27, 2023, Order and permit Plaintiffs until January 9, 2024, to file any necessary motions to compel 

with respect to: (1) Defendant HCI’s supplemental production produced pursuant to this Court’s 

Order No. 133 entered October 27, 2023; (2) Defendant Florian Education Investor’s November 

22, 2023, and December 1, 2023, Responses to Plaintiffs’ Second Set of Requests for Production; 

and (3) Defendant HCI’s December 1, 2023, Responses to Plaintiffs’ Third Set of Requests for 

Production.

Case 9:22-cv-81883-RAR Document 147 Entered on FLSD Docket 12/29/2023 Page 2 of 3
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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: December 29, 2023

Respectfully submitted,

/s/ Nicole Mayer

NICOLE MAYER 

MAYER LAW PLLC

Florida Bar No. 012035

Nicole@MayerLawFlorida.com

171 Dommerich Drive

Maitland, Florida 32751

(352) 494-3657

JENNIFER THELUSMA

Florida Bar No. 1019776

jthelusma@ppsl.org

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 160

Jamaica Plain, MA 02130

(617) 390-2669

Attorneys for Plaintiffs

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