On June 17, 2021 a
Party Discovery
was filed
involving a dispute between
James N Manolakos,
and
City Of West Palm Beach,
Ronald Paul Himeback,
Safeco Insurance Company Of Illinois,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
Preview
Filing # 140035660 E-Filed 12/09/2021 12:11:49 PM
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY,
FLORIDA.
CASE NO: 50-2021-CA-007517-XXXX-MB
JAMES N. MANOLAKOS,
Plaintiff,
vs.
RONALD PAUL HIMEBACK,
Defendant.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME
ON DEFENDANT’S 11-09-21 INTERROGATORIES
Plaintiff, JAMES N. MANOLAKOS (hereinafter Plaintiff), by and through his
undersigned attorneys, for extension of time to answer the 11-09-21
interrogatories of Defendant RONALD PAUL HIMEBACK (hereinafter
Defendant) and moves for a protective order and for grounds states as follows:
1. This matter is currently not set for trial.
Talre dant areal tntawnn natantnn a ae cha 11 ANAL
VTLCUUALLL STLVEU LILCLIOBALOLICS Oli OF ADOUL L1-UY-Z1.
9
2.
3. From the very inception of this case Plaintiff's counsel has been attempting
to schedule depositions related to the subject which Defendant seeks answers to
interrogatories
interro gatories,
4. Plaintiff had depositions rescheduled and then canceled at the request of the
City of West Palm Beach and/or Defendant on more than one occasion.
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDY 49INAINNN 49.44.40 DMA
PILL. PAL DUA VUUINE TT, PL, vUOL II mDnuecy, ULL, Ierugeue! 12.1 to ci5. Defendant cannot expect Plaintiff to answer the type of interrogatories
being propounded without a full and fair opportunity for Plaintiff to do discovery.
6. Defendant would not be prejudiced by an extension given the above facts.
7. The interrogatories may involve objectionable matter. Accordingly,
Plaintiff request that the extension include time to file any objections.
MEMO OF LAW
Fla. R. Civ. Pro. 1.340(a) states that the “court may allow a shorter or
longer time” to answer interrogatories. Plaintiff requests that the court allow an
additional thirty (30) days to file answers after the previously scheduled
depositions have been concluded, including any objections.
WHEREFORE, Plaintiff requests the court’s order granting an extension of
time as set forth above, including any objections.
Thereby certify that on this G day of December, 2021 a true and accurate copy of the
Torgoing was e-served by filing it with the Circuit Court and furnished by email to:
dstephens@oslegal.com, LOlds@oslegal.com, volds@oslegal.com,
agagnon@oslegal.com PPecaro@lawdrive.com and gigi@lawdrive.com.
Philip Alain Stillman, Esa,
Bader Stillman, P.L.
6100 W Atlantic Blvd #5 and
Margate, FL 33063
Tel: (954) 971-3399
phil@baderstillman.com
Florida Bar No.: 653860
Dieon C, Asencin PA
BU We EROUHIOLU, deeds
4440 PGA Blvd. Suite 600
Palm Beach Gardens, FL 33410
Tel: es en
Email; diego634¢@ag
By: Cre
Di edb C. Asencio, Esa.
Florida Bar No.: 352942
Document Filed Date
December 09, 2021
Case Filing Date
June 17, 2021
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Filing # 140035660 E-Filed 12/09/2021 12:11:49 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO: 50-2021-CA-007517-XXXX-MB JAMES N. MANOLAKOS, Plaintiff, vs. RONALD PAUL HIMEBACK, Defendant. / PLAINTIFF’S MOTION FOR EXTENSION OF TIME ON DEFENDANT’S 11-09-21 INTERROGATORIES Plaintiff, JAMES N. MANOLAKOS (hereinafter Plaintiff), by and through his undersigned attorneys, for extension of time to answer the 11-09-21 interrogatories of Defendant RONALD PAUL HIMEBACK (hereinafter Defendant) and moves for a protective order and for grounds states as follows: 1. This matter is currently not set for trial. Talre dant areal tntawnn natantnn a ae cha 11 ANAL VTLCUUALLL STLVEU LILCLIOBALOLICS Oli OF ADOUL L1-UY-Z1. 9 2. 3. From the very inception of this case Plaintiff's counsel has been attempting to schedule depositions related to the subject which Defendant seeks answers to interrogatories interro gatories, 4. Plaintiff had depositions rescheduled and then canceled at the request of the City of West Palm Beach and/or Defendant on more than one occasion. CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDY 49INAINNN 49.44.40 DMA PILL. PAL DUA VUUINE TT, PL, vUOL II mDnuecy, ULL, Ierugeue! 12.1 to ci5. Defendant cannot expect Plaintiff to answer the type of interrogatories being propounded without a full and fair opportunity for Plaintiff to do discovery. 6. Defendant would not be prejudiced by an extension given the above facts. 7. The interrogatories may involve objectionable matter. Accordingly, Plaintiff request that the extension include time to file any objections. MEMO OF LAW Fla. R. Civ. Pro. 1.340(a) states that the “court may allow a shorter or longer time” to answer interrogatories. Plaintiff requests that the court allow an additional thirty (30) days to file answers after the previously scheduled depositions have been concluded, including any objections. WHEREFORE, Plaintiff requests the court’s order granting an extension of time as set forth above, including any objections. Thereby certify that on this G day of December, 2021 a true and accurate copy of the Torgoing was e-served by filing it with the Circuit Court and furnished by email to: dstephens@oslegal.com, LOlds@oslegal.com, volds@oslegal.com, agagnon@oslegal.com PPecaro@lawdrive.com and gigi@lawdrive.com. Philip Alain Stillman, Esa, Bader Stillman, P.L. 6100 W Atlantic Blvd #5 and Margate, FL 33063 Tel: (954) 971-3399 phil@baderstillman.com Florida Bar No.: 653860 Dieon C, Asencin PA BU We EROUHIOLU, deeds 4440 PGA Blvd. Suite 600 Palm Beach Gardens, FL 33410 Tel: es en Email; diego634¢@ag By: Cre Di edb C. Asencio, Esa. Florida Bar No.: 352942