Document for Tower Hill Prime Insurance Company Vs Gorman, Timothy

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                                Filing # 110031268 E-Filed 07/09/2020 04:46:16 PM

IN THE CIRCUIT COURT OF THE

TWENTIETH JUDICIAL CIRCUIT IN AND

FOR COLLIER COUNTY, FLORIDA

CASE NO.: 2019-CA-4995

TIMOTHY GORMAN AND CATHERINE GORMAN,
Plaintiffs,

vs.

TOWER HILL PRIME INSURANCE COMPANY,

Defendant.
/

PLAINTIFFS’ MOTION FOR ENLARGEMENT OF TIME
TO RESPOND AND/OR OBJECT TO DEFENDANT’S DISCOVERY REQUESTS

Plaintiffs, TIMOTHY GORMAN and CATHERINE GORMAN, by and through the undersigned
counsel, and pursuant to Fla. R. Civ. P. 1.090(b) and other applicable Rules of Civil Procedure, hereby file and
serve its Motion for Enlargement of Time to Respond and/or Object to Defendant’s First Request for Production
and First Set of Interrogatories, and in furtherance state as follows:

1. Defendant served its discovery requests on or about June 9, 2020.

2. Under Fla. R. Civ. P. 1.350, Plaintiffs’ response and/or objection are due by July 9, 2020.

3. Plaintiffs are in the process of preparing responses and/or objections to Defendant’s First Set of
Interrogatories and First Request for Production and respectfully requests a twenty-day enlargement of time to
respond and/or object to Defendant’s Requests.

4. Fla. R. Civ. P. 1.090(b) grants discretion to this Honorable Court to enlarge the time permitted
for Plaintiffs to prepare discovery responses and/or objections.

5. Fla. R. Civ. P. 1.280 and the Court’s inherent authority to control and manage discovery also
permit this Honorable Court to enlarge the time permitted for Plaintiff to prepare discovery responses and/or
objections. See The Florida Bar v. Berthiaume, 78 So. 3d 503, 508 (Fla. 2011), reh'g denied (Jan. 10, 2012)

(“Courts have authority to control discovery in all aspects ...”).

FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/09/2020 04:46:16 PM6. Plaintiffs’ Motion for Enlargement of Time is being filed in good faith and not for purposes of
delay.

WHEREFORE, Plaintiffs, TIMOTHY GORMAN and CATHY GORMAN, respectfully request
that This Honorable Court enter an Order enlarging the period of time to respond and/or to object Defendant’s
First Request for Production and First Set of Interrogatories until July 29, 2020, and for any and all other relief
the Court deems just.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent on this 9th day of
July 2020, via e-mail, in accordance with Rule 2.516, Florida Rules of Judicial Administration to:
Howard W. Holden, Esq., and Brittany P. Cocchieri, Esq., 1422 Hendry Street, Third Floor, Fort Myers,
FL 33901, LUKSFTM-Pleadings@Is-law.com, BCocchieri@insurancedefense.net.

GEYER FUXA TYLER

490 Sawgrass Corporate Parkway, Ste. 110
Sunrise, FL 33325

(954) 990-5251; Fax: (954) 990-4346
Attorneys for Plaintiff

Pleadings! lawfirm.com

/s/ Kathleen M. O’Brien
Jeremy F. Tyler, Esq.
Florida Bar No.: 77115
Kathleen M. O’Brien, Esq.
Florida Bar No.: 91195