MOTION FOR EXTENSION OF TIME

• 
• 
• 
• 
• 
• 

                        

						    Preview
                        
                        
                          Filing # 121418744 E-Filed 02/15/2021 06:06:52 PM

IN THE COUNTY COURT OF THE SECOND JUDICIAL CIRCUIT
IN AND FOR GADSDEN COUNTY, FLORIDA

CHARLES PRESIDENT,
CASE NO.: 21-000001-CC
Petitioner,

ve

FOREMOST INSURANCE COMPANY
GRAND RAPIDS, MICHIGAN,

Respondent.
/

DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO THE COMPLAINT

Defendant, Foremost Insurance Company Grand Rapids, Michigan (“Foremost”),
moves for an enlargement of time to respond to the complaint, and states:

1. Foremost was served with the complaint on January 25, 2021.

2. Foremost’s response to the complaint is due to be served today.

3. Foremost and its counsel have been diligently working to formulate a proper
response to the complaint.

4. Despite that diligent effort, Foremost and its counsel need additional time to
formulate a proper response.

5. Fla. R. Civ. P. 1.090 allows for an enlargement of time upon cause shown so
long as the motion for the enlargement of time is made within the period to be
enla…