On January 20, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Mondejar, Omarys,
Presgar Imaging Of Cmi South, L.C.,
and
Infinity Auto Insurance Company, A Foreign Corporation,
for Civil
in the District Court of Hillsborough County.
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Filing # 123301246 E-Filed 03/18/2021 07:37:21 AM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLBOROUGH COUNTY, FLORIDA
SMALL CLAIMS DIVISION
PRESGAR IMAGING OF CMI SOUTH, L.C.,
a/a/o OMARYS MONDEJAR,
Plaintiff,
v. CASE NO.: 21-CC-005603
DIVISION: S
INFINITY AUTO INSURANCE COMPANY,
Defendant
__________________________________________/
MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S DISCOVERY TO DEFENDANT
COMES now Defendant, by and through its undersigned attorney, and hereby files this
Motion for Extension of Time to Respond to Plaintiff’s Discovery to Defendant, and hereby
requests that this Honorable Court enter an order extending the time in which the Defendant
must respond to the Plaintiff’s First Request for Production and in support thereof states as
follows:
1. Plaintiff herein has filed a Personal Injury Protection lawsuit.
2. Plaintiff also served discovery requests on the Defendant.
3. The undersigned counsel requests additional time to file a response to Plaintiff’s
Discovery Requests and states Defendant has not previously requested an enlargement of time to
respond to discovery in this matter.
4. This Motion is not being made for the purposes of delay and Plaintiff will not be
prejudiced by this request.
5. Pursuant to Rules 1.340, 1.350 and 1.370, Fla. R. Civ. P., this court is empowered
to grant an extension of time for the Defendant to respond to the Plaintiff’s discovery
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3/18/2021 7:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
requests pursuant to the Florida Rules of Civil Procedure.
WHEREFORE, the Defendant requests that this Honorable Court enter an order
extending the time in which the Defendant must respond to the Plaintiff’s First Request for
Production and based upon the foregoing facts and law, and any other relief deemed just and
proper.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via email service through the Florida Court’s E-filing Portal on March 18, 2021 to: Philip A.
Friedman Esquire, FL Legal Group at PAFriedman@FLLegalGroup.com and
Filings@FLLegalGroup.com.
LAW OFFICE OF GABRIEL O. FUNDORA
& ASSOCIATES
Employees of Infinity Insurance Company
A Kemper Corporation Affiliate
506 W Fletcher Ave., Suite 101
Tampa, FL 33612
T: (813) 280-3180
F: (813) 280-3201
Service Email: TampaLegal@ipacc.com
By: /s/ Rebecca A. Glenn
Rebecca A. Glenn, Esquire
Florida Bar No.: 115469
2
3/18/2021 7:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
March 18, 2021
Case Filing Date
January 20, 2021
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Filing # 123301246 E-Filed 03/18/2021 07:37:21 AM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLBOROUGH COUNTY, FLORIDA SMALL CLAIMS DIVISION PRESGAR IMAGING OF CMI SOUTH, L.C., a/a/o OMARYS MONDEJAR, Plaintiff, v. CASE NO.: 21-CC-005603 DIVISION: S INFINITY AUTO INSURANCE COMPANY, Defendant __________________________________________/ MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S DISCOVERY TO DEFENDANT COMES now Defendant, by and through its undersigned attorney, and hereby files this Motion for Extension of Time to Respond to Plaintiff’s Discovery to Defendant, and hereby requests that this Honorable Court enter an order extending the time in which the Defendant must respond to the Plaintiff’s First Request for Production and in support thereof states as follows: 1. Plaintiff herein has filed a Personal Injury Protection lawsuit. 2. Plaintiff also served discovery requests on the Defendant. 3. The undersigned counsel requests additional time to file a response to Plaintiff’s Discovery Requests and states Defendant has not previously requested an enlargement of time to respond to discovery in this matter. 4. This Motion is not being made for the purposes of delay and Plaintiff will not be prejudiced by this request. 5. Pursuant to Rules 1.340, 1.350 and 1.370, Fla. R. Civ. P., this court is empowered to grant an extension of time for the Defendant to respond to the Plaintiff’s discovery 1 3/18/2021 7:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 requests pursuant to the Florida Rules of Civil Procedure. WHEREFORE, the Defendant requests that this Honorable Court enter an order extending the time in which the Defendant must respond to the Plaintiff’s First Request for Production and based upon the foregoing facts and law, and any other relief deemed just and proper. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via email service through the Florida Court’s E-filing Portal on March 18, 2021 to: Philip A. Friedman Esquire, FL Legal Group at PAFriedman@FLLegalGroup.com and Filings@FLLegalGroup.com. LAW OFFICE OF GABRIEL O. FUNDORA & ASSOCIATES Employees of Infinity Insurance Company A Kemper Corporation Affiliate 506 W Fletcher Ave., Suite 101 Tampa, FL 33612 T: (813) 280-3180 F: (813) 280-3201 Service Email: TampaLegal@ipacc.com By: /s/ Rebecca A. Glenn Rebecca A. Glenn, Esquire Florida Bar No.: 115469 2 3/18/2021 7:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2