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.
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Filing # 140035660 E-Filed 12/09/2021 12:11:49 PM
IN THE CIRCUIT COURT OF THE 15TH
TUDICTAT CIRCUIT IN AND FOR PATM
Vaan a faa aka ae
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 11-09-2021 REQUEST TO PRODUCE
Plaintiff, JAMES N. MANOLAKOS (hereinafter Plaintiff), by and through
his undersigned attorneys, moves for extension of time on the Defendant RONALD
PAUL HIMEBACK’S 11-09-21 supplemental request to produce, and for a
protective order, and for grounds states as follows:
1 Thin enadhae fa arenentler ead wat Soe tet at
Le 11D LUALLEL 15 CULICLILLY MOL SCL LOL Ula.
2. Defendant RONALD PAUL HIMEBACK (hereinafter Defendant) served a
supplemental request to produce on or about 11-09-21.
3 From the verv incention of this cace Plaintiff s conncal hac haen attamnting to
2: OFY NCOP Ucn Cr us Case saat S COUnSe: mas OCOn auciipulg, to
schedule depositions related to the subject on which Defendant seeks production.
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 respond to the type of requests being
made without a full and fair opportunity for Plaintiff to do the subject discovery.
6. Defendant would not be prejudiced by an extension given the above facts.
{fs The supplemental request to produce may involve objectionable matter.
Accordingly, Plaintiff request that the extension include time to file any objections.
MEMO OF LAW
Fla. R. Civ. Pro. 1.350(a) states that the “court may allow a shorter or longer
time” for response to request to produce. Plaintiff requests that the court allow an
additional thirty (30) days to file a response from the date the previously scheduled
deposition are concluded, including any objections.
‘WHEREFORE, Plaintiff requests the court’s order that Plaintiff
granting extension as requested above, including any objections.
Thereby certify that on this Sy of December, 2021 a true and accurate copy of
the forgoing 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@poslegal.com PPecaro@lawdrive.com and gigi@lawdrive.com.
Philip Alain Stillman, Esq. Diego C. Asencio, P.A.
Bader Stiliman, P.L. 4440 PGA Bivd. Suite 600
6100 W Atlantic Blvd #5 and Palm Beach Gardens, FL 33410
Margate, FL 33063 Tel: 56 1) 844- 0840
Tel: (954) 971-3399 il:
phil@baderstillman.com
Florida Bar No.: 653860
Di BO c. Asencio, DSq.
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 TUDICTAT CIRCUIT IN AND FOR PATM Vaan a faa aka ae 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 11-09-2021 REQUEST TO PRODUCE Plaintiff, JAMES N. MANOLAKOS (hereinafter Plaintiff), by and through his undersigned attorneys, moves for extension of time on the Defendant RONALD PAUL HIMEBACK’S 11-09-21 supplemental request to produce, and for a protective order, and for grounds states as follows: 1 Thin enadhae fa arenentler ead wat Soe tet at Le 11D LUALLEL 15 CULICLILLY MOL SCL LOL Ula. 2. Defendant RONALD PAUL HIMEBACK (hereinafter Defendant) served a supplemental request to produce on or about 11-09-21. 3 From the verv incention of this cace Plaintiff s conncal hac haen attamnting to 2: OFY NCOP Ucn Cr us Case saat S COUnSe: mas OCOn auciipulg, to schedule depositions related to the subject on which Defendant seeks production. 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 respond to the type of requests being made without a full and fair opportunity for Plaintiff to do the subject discovery. 6. Defendant would not be prejudiced by an extension given the above facts. {fs The supplemental request to produce may involve objectionable matter. Accordingly, Plaintiff request that the extension include time to file any objections. MEMO OF LAW Fla. R. Civ. Pro. 1.350(a) states that the “court may allow a shorter or longer time” for response to request to produce. Plaintiff requests that the court allow an additional thirty (30) days to file a response from the date the previously scheduled deposition are concluded, including any objections. ‘WHEREFORE, Plaintiff requests the court’s order that Plaintiff granting extension as requested above, including any objections. Thereby certify that on this Sy of December, 2021 a true and accurate copy of the forgoing 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@poslegal.com PPecaro@lawdrive.com and gigi@lawdrive.com. Philip Alain Stillman, Esq. Diego C. Asencio, P.A. Bader Stiliman, P.L. 4440 PGA Bivd. Suite 600 6100 W Atlantic Blvd #5 and Palm Beach Gardens, FL 33410 Margate, FL 33063 Tel: 56 1) 844- 0840 Tel: (954) 971-3399 il: phil@baderstillman.com Florida Bar No.: 653860 Di BO c. Asencio, DSq. Florida Bar No.: 352942