On April 09, 2021 a
Hearing
was filed
involving a dispute between
Progressive Northern Insurance Company,
and
Hallmark Insurance Company,
for Civil
in the District Court of Hillsborough County.
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Filing # 146097156 E-Filed 03/21/2022 02:41:32 PM
IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.: 21-CC-034076
PROGRESSIVE NORTHERN INSURANCE COMPANY
Plaintiff,
v.
HALLMARK INSURANCE COMPANY,
Defendant.
___________________________________/
PLAINTIFF’S MOTION FOR ZOOM VIDEO
CONFERENCE APPEARANCE AT A HEARING
COMES NOW Plaintiff PROGRESSIVE NORTHERN INSURANCE COMPANY, by
and through its undersigned counsel, and pursuant to the Florida Rules of Civil Procedure hereby
files this Motion for Zoom Video Conference Appearance at a Hearing and as grounds states as
follows:
1. Plaintiff’s counsel is scheduled to appear before the Honorable Jack N. Gutman at
the Hillsborough County Courthouse - Edgecomb Courthouse, 800 E. Twiggs Street, Room 306,
Tampa, FL 33602 at 10:45am ET relative to Plaintiff’s Motion to Confirm Arbitration Award, to
Determine Rights to Attorney’s Fees, and for Entry of Judgment.
2. This motion is made pursuant to Section 682.12 and Section 682.15, Florida
Statutes.
3. Due to Plaintiff’s counsel working from home and the ongoing COVID-19
pandemic, Plaintiff’s counsel seeks to appear remotely via Zoom Video Conferencing.
4. Defendant will not be prejudiced in this matter if counsel is allowed to participate
by way of Zoom Video Conferencing.
3/21/2022 2:41 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
Respectfully submitted on this March 21, 2022.
__/s/Joseph C. Proulx___________
Joseph C. Proulx, Esq.
Florida Bar No.: 0056830
GOLDEN SCAZ GAGAIN, PLLC
1135 Marbella Plaza Drive
Tampa, Florida 33619
Phone: (813) 251-3668
Fax: (813) 251-3675
jproulx@gsgfirm.com
Attorneys for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 21, 2022, a copy of the foregoing was served via
the E- Filing Portal System to all Counsel of Record:
Jarod L. Gilbert
Florida Bar No.: 0055869
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) 280-3181 / F: (813) 280-3201
Service Email: TampaLegal@ipacc.com
/s/ Joseph C. Proulx
Joseph C. Proulx, Esq.
FBN: 0056830
3/21/2022 2:41 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
Document Filed Date
March 21, 2022
Case Filing Date
April 09, 2021
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Filing # 146097156 E-Filed 03/21/2022 02:41:32 PM IN THE COUNTY COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 21-CC-034076 PROGRESSIVE NORTHERN INSURANCE COMPANY Plaintiff, v. HALLMARK INSURANCE COMPANY, Defendant. ___________________________________/ PLAINTIFF’S MOTION FOR ZOOM VIDEO CONFERENCE APPEARANCE AT A HEARING COMES NOW Plaintiff PROGRESSIVE NORTHERN INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to the Florida Rules of Civil Procedure hereby files this Motion for Zoom Video Conference Appearance at a Hearing and as grounds states as follows: 1. Plaintiff’s counsel is scheduled to appear before the Honorable Jack N. Gutman at the Hillsborough County Courthouse - Edgecomb Courthouse, 800 E. Twiggs Street, Room 306, Tampa, FL 33602 at 10:45am ET relative to Plaintiff’s Motion to Confirm Arbitration Award, to Determine Rights to Attorney’s Fees, and for Entry of Judgment. 2. This motion is made pursuant to Section 682.12 and Section 682.15, Florida Statutes. 3. Due to Plaintiff’s counsel working from home and the ongoing COVID-19 pandemic, Plaintiff’s counsel seeks to appear remotely via Zoom Video Conferencing. 4. Defendant will not be prejudiced in this matter if counsel is allowed to participate by way of Zoom Video Conferencing. 3/21/2022 2:41 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 Respectfully submitted on this March 21, 2022. __/s/Joseph C. Proulx___________ Joseph C. Proulx, Esq. Florida Bar No.: 0056830 GOLDEN SCAZ GAGAIN, PLLC 1135 Marbella Plaza Drive Tampa, Florida 33619 Phone: (813) 251-3668 Fax: (813) 251-3675 jproulx@gsgfirm.com Attorneys for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 21, 2022, a copy of the foregoing was served via the E- Filing Portal System to all Counsel of Record: Jarod L. Gilbert Florida Bar No.: 0055869 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) 280-3181 / F: (813) 280-3201 Service Email: TampaLegal@ipacc.com /s/ Joseph C. Proulx Joseph C. Proulx, Esq. FBN: 0056830 3/21/2022 2:41 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2