On April 27, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Fedrick, Erlene,
and
Arch Insurance Company,
Henes, Patrick Donald,
for Circuit Civil
in the District Court of Lake County.
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Filing # 151397745 E-Filed 06/13/2022 04:07:06 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,
IN AND FOR LAKE COUNTY, FLORIDA
ERLENE FEDRICK, CASE NO.: 2022-CA-000754
Plaintiff,
Vv.
PATRICK DONALD HENES and
ARCH INSURANCE COMPANY,
Defendants.
/
DEFENDANT ARCH INSURANCE COMPANY’S MOTION FOR EXTENSION OF
TIME TO RESPOND TO DISCOVERY
Defendant, ARCH INSURANCE COMPANY (“ARCH”), by and through its undersigned
counsel, moves this Court for the entry of an Order Granting an Extension of Time to Respond to
Discovery propounded on April 27, 2022, and as grounds therefore states:
1 On April 27, 2022 the Plaintiff filed suit against ARCH.
2. Served with Plaintiff's Complaint to ARCH were first sets of Interrogatories,
Requests to Produce, and Requests for Admissions.
3 ARCH’s response to Plaintiff's discovery is due today, June 13, 2022.
4 ARCH’s internal legal team is reviewing the undersigned’s proposed discovery
responses, and needs more time to complete its review.
5 The undersigned has contacted Plaintiffs counsel to request an extension of time
to serve ARCH’s responses. At present, Plaintiffs counsel has not responded to the request.
6 ARCH respectfully requests an extension of time until June 20, 2022 to respond to
Plaintiff’s discovery.
7 This request is not made for the purpose of undue delay.
8 Granting the instant Motion will not prejudice any party to this lawsuit.
33653377.v1
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/13/2022 04:53:13 PM.
9 The undersigned counsel will attempt to resolve this matter with opposing counsel
prior to setting this motion for hearing.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that the foregoing has been electronically filed and served via
Florida ePortal to: Devry R. Kelly, Esq., Dan Newlin Injury Attorneys, 7335 W. Sand Lake Road,
Suite 300, Orlando, FL 32819 at devry.kelley@newlinlaw.com; patricia.croc@newlinlaw.com;
devry.pleadings@newlinlaw.com; (Plaintiffs counsel); and Ayda Kapsales, Esq.; Law Office of
Terryl Blackmon Walker; 901 N. Lake Destiny Rd., Suite 105, Maitland, FL 32751;
NOFLBI@progressive.com and akapsall @progressive.com; on June 13, 2022.
GOLDBERG SEGALLA, LLP
800 North Magnolia Ave., Suite 450
Orlando, FL 32803
Telephone: (407)458-5600
/s/ Troy Beecher
Troy Beecher, Esquire
Florida Bar No.: 37348
Email: theecher@goldbersegalla.com
sherndon@goldbergsegalla.com;
psouza@golbergsegalla.com
33653377.v1
Document Filed Date
June 13, 2022
Case Filing Date
April 27, 2022
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Filing # 151397745 E-Filed 06/13/2022 04:07:06 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA ERLENE FEDRICK, CASE NO.: 2022-CA-000754 Plaintiff, Vv. PATRICK DONALD HENES and ARCH INSURANCE COMPANY, Defendants. / DEFENDANT ARCH INSURANCE COMPANY’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY Defendant, ARCH INSURANCE COMPANY (“ARCH”), by and through its undersigned counsel, moves this Court for the entry of an Order Granting an Extension of Time to Respond to Discovery propounded on April 27, 2022, and as grounds therefore states: 1 On April 27, 2022 the Plaintiff filed suit against ARCH. 2. Served with Plaintiff's Complaint to ARCH were first sets of Interrogatories, Requests to Produce, and Requests for Admissions. 3 ARCH’s response to Plaintiff's discovery is due today, June 13, 2022. 4 ARCH’s internal legal team is reviewing the undersigned’s proposed discovery responses, and needs more time to complete its review. 5 The undersigned has contacted Plaintiffs counsel to request an extension of time to serve ARCH’s responses. At present, Plaintiffs counsel has not responded to the request. 6 ARCH respectfully requests an extension of time until June 20, 2022 to respond to Plaintiff’s discovery. 7 This request is not made for the purpose of undue delay. 8 Granting the instant Motion will not prejudice any party to this lawsuit. 33653377.v1 FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 06/13/2022 04:53:13 PM. 9 The undersigned counsel will attempt to resolve this matter with opposing counsel prior to setting this motion for hearing. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that the foregoing has been electronically filed and served via Florida ePortal to: Devry R. Kelly, Esq., Dan Newlin Injury Attorneys, 7335 W. Sand Lake Road, Suite 300, Orlando, FL 32819 at devry.kelley@newlinlaw.com; patricia.croc@newlinlaw.com; devry.pleadings@newlinlaw.com; (Plaintiffs counsel); and Ayda Kapsales, Esq.; Law Office of Terryl Blackmon Walker; 901 N. Lake Destiny Rd., Suite 105, Maitland, FL 32751; NOFLBI@progressive.com and akapsall @progressive.com; on June 13, 2022. GOLDBERG SEGALLA, LLP 800 North Magnolia Ave., Suite 450 Orlando, FL 32803 Telephone: (407)458-5600 /s/ Troy Beecher Troy Beecher, Esquire Florida Bar No.: 37348 Email: theecher@goldbersegalla.com sherndon@goldbergsegalla.com; psouza@golbergsegalla.com 33653377.v1