Motion-Secondary: MRI ASSOCIATES OF LAKELAND LLC,HANNA, FRANKLIN vs PROGRESSIVE SELECT INSURANCE COMPANY, a foreign corporation

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                                Filing # 128077635 E-Filed 06/03/2021 06:09:22 PM


                   IN     THE      COUNTY          COURT        OF     THE
                   THIRTEENTH JUDICIAL CIRCUIT IN AND
                   FOR HILLSBOROUGH COUNTY, FLORIDA


                   MRI ASSOCIATES OF LAKELAND LLC, as
                   assignee of Franklin Hanna,

                   Plaintiff
                   v.                                                           CASE NO: 21-CC-032133 (K)
                   PROGRESSIVE              SELECT          INSURANCE           CIVIL DIVISION
                   COMPANY, a foreign corporation,

                   Defendant.
                                                                        /


                           DEFENDANT'S MOT10N FOR EXTENSION OF TIME TO RESPOND TO
                                    PLAINTIFFS' DISCOVERY AND NOTICE OF OBJECTIONS

                          COMES now, the Defendant, PROGRESSIVE SELECT INSURANCE COMPANY, by

                  and through its undersigned counsel and pursuant to Florida Rules of Civil Procedure l.090(b),

                  hereby files this Motion for Extension of Time for Defendant to serve responses to the discovery

                  served with the Complaint (Request for Production) and in support states as follows:

                           1.       The full claim materials are not currently in possession and the defense needs

                  time to consult with its client in order to prepare discovery responses.

                           2.       In the event this motion is denied, in an abundance of caution, the Defendant

                  hereby raises timely objections to each and every request for production, interrogatory, and

                  request for admission on the grounds that the information request is overbroad, irrelevant,

                  harassing, seeks disclosure of confidential and/or protected proprietary information, seeks

                  documents protected by work product and/or documents prepared in anticipation of litigation and

                  is not reasonably calculated to lead to admissible evidence. The Defendant reserves the right to

                  withdraw and/or amend these objections.




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                                                                                                 CASE NO: 21-CC-032133 (K)


                           3.       Plaintiff will suffer no prejudice from this extension of time.

                           WHEREFORE, Defendant, respectfully requests that this Court enter an Order granting

                  additional time within which to file responses and amended objections to the Plaintiff' s Request

                  for Production.

                                                         CERTIFICATE OF SERVICE

                           I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
                  furnished via E-Mail on June 3, 2021 to Philip A. Friedman, Esquire, Fl Legal Group, Attorney
                  for     Plaintiff      MRI       Associates       of    Lakeland,        LLC.,      a/a/o     Franklin      Hanna,
                  filings@FLLegalGroup.com, KAWashington@FLLegalGroup.com, (813) 221-9500/(813) 341-
                  6898 (F).

                                                                          Progressive PIP House Counsel
                                                                          Attorneys for Defendant
                                                                          600 N. Westshore Blvd, Suite 300
                                                                          Tampa, FL 33609
                                                                           (Asst.)/(813) 371-4208 (Direct)
                                                                          Fax: (813) 289-5347
                                                                          SERVICE DESIGNATIONS:
                                                                          Primary: TampaPIPHC 1 @Progressive.com
                                                                          Secondary: Michae1_E_Bringuier@Progressive.com



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                                                                          By:

                                                                                MICHAEL E. BRINGUIER, ESQUIRE
                                                                                Florida Bar No. 97825
                                                                                "Safaried Empuloyees ofP:ogJ@ssive Casualty Insuranc@ Company




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