On September 21, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Redondo, Jeudy,
Shazam Auto Glass, Llc,
and
Progressive Select Insurance Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 154204108 E-Filed 07/27/2022 06:45:36 PM
IN THE COUNTY COURT IN
AND FOR HILLSBOROUGH
COUNTY, FLORIDA
SHAZAM AUTO GLASS, LLC CASE NO.: 21-CC-097748
(a/a/o JEUDY REDONDO),
Plaintiff,
vs.
PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendant.
_____________________________________/
DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
PLAINTIFF'S DISCOVERY REQUESTS
COMES NOW, the Defendant, PROGRESSIVE, by and through its undersigned counsel,
and pursuant to Florida Rule of Civil Procedure 1.090, moves for an Enlargement of Time for
Defendant to serve a response to Plaintiff’s requests for discovery, and in support states as follows:
1. The undersigned counsel was recently assigned to the defense of this suit.
2. At this juncture, the full claim materials are not currently in possession and the
defense needs time to consult with its client in order to prepare a response to Plaintiff’s
Interrogatories and Request for Admissions.
3. Plaintiff will suffer no prejudice from this extension of time.
WHEREFORE, the Defendant respectfully requests that this Court enter an Order granting
additional time within which to file a response to Plaintiff’s requests for discovery.
1
7/27/2022 6:45 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy of the foregoing has been furnished via EPORTAL
to Anthony T. Prieto Esq., 3705 North Himes Avenue Tampa, Florida 33607
(aprieto@fothepeople.com)(ameliafloyd@forthepeople.com); this 27th day of July, 2022.
BOYD & JENERETTE, P.A.
/s/ Geneva R. Fountain
GENEVA R. FOUNTAIN
Florida Bar No. 117723
gfountain@boydjen.com
201 N. Hogan St., Suite 400
Jacksonville, FL 32202
(904) 353-6241 - Telephone
VICTORIA M. CABRERA
Florida Bar No. 123034
vcabrera@boydjen.com
800 N. Magnolia Ave. Ste. 430
Orlando, FL 32803
(904) 326-0443 - Telephone
Counsel for Defendant
2
7/27/2022 6:45 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
July 27, 2022
Case Filing Date
September 21, 2021
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Filing # 154204108 E-Filed 07/27/2022 06:45:36 PM IN THE COUNTY COURT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA SHAZAM AUTO GLASS, LLC CASE NO.: 21-CC-097748 (a/a/o JEUDY REDONDO), Plaintiff, vs. PROGRESSIVE SELECT INSURANCE COMPANY, Defendant. _____________________________________/ DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS COMES NOW, the Defendant, PROGRESSIVE, by and through its undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.090, moves for an Enlargement of Time for Defendant to serve a response to Plaintiff’s requests for discovery, and in support states as follows: 1. The undersigned counsel was recently assigned to the defense of this suit. 2. At this juncture, the full claim materials are not currently in possession and the defense needs time to consult with its client in order to prepare a response to Plaintiff’s Interrogatories and Request for Admissions. 3. Plaintiff will suffer no prejudice from this extension of time. WHEREFORE, the Defendant respectfully requests that this Court enter an Order granting additional time within which to file a response to Plaintiff’s requests for discovery. 1 7/27/2022 6:45 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy of the foregoing has been furnished via EPORTAL to Anthony T. Prieto Esq., 3705 North Himes Avenue Tampa, Florida 33607 (aprieto@fothepeople.com)(ameliafloyd@forthepeople.com); this 27th day of July, 2022. BOYD & JENERETTE, P.A. /s/ Geneva R. Fountain GENEVA R. FOUNTAIN Florida Bar No. 117723 gfountain@boydjen.com 201 N. Hogan St., Suite 400 Jacksonville, FL 32202 (904) 353-6241 - Telephone VICTORIA M. CABRERA Florida Bar No. 123034 vcabrera@boydjen.com 800 N. Magnolia Ave. Ste. 430 Orlando, FL 32803 (904) 326-0443 - Telephone Counsel for Defendant 2 7/27/2022 6:45 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2