On April 07, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Ingrid Valentine,
and
Main Street America Assurance Company,
Main Street America Protection Insurance Company,
for Contract and Indebtedness Division: CV-D
in the District Court of Duval County.
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Filing # 115405143 E-Filed 10/21/2020 06:23:58 PM
IN THE CIRCUIT COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
INGRID VALENTINE,
PLAINTIFF, CASE NO.: 16-2020-CA-002061-XXXX-MA
vs.
MAIN STREET AMERICA PROTECTION
INSURANCE COMPANY; MAIN STREET
AMERICA ASSURANCE COMPANY,
DEFENDANTS.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO
DEFENDANT’S SECOND DISCOVERY REQUESTS
COMES NOW, the Plaintiff, Ingrid Valentine, (hereinafter “Plaintiff(s)”), by and through
the undersigned Attorney, and files this Motion for Extension of Time to File Responses to
Defendant’s Second Discovery Request(s). As grounds therefore and in support thereof, the
Plaintiff(s) would state as follows:
1 This is an action for breach of contract and statutory duties, seeking damages which do
exceed $30,000.00 exclusive of costs, interest, and attorneys’ fees.
2. The Plaintiff filed a Complaint against Defendant.
3 After having been served with said Complaint, the Defendant filed discovery requests
directed towards Plaintiffs.
4 Plaintiff responded to Defendant’s initial discovery requests.
5 Defendant has taken the deposition of Plaintiff.
6 Defendant has also compounded a second set of discovery requests on Plaintiff.
7 Plaintiff is in need of additional time to respond to the second round of discovery
requests propounded on Plaintiff by Defendant.
ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 10/23/2020 07:54:42 AM.
8 This Motion is not made for the purposes of harassment or delay.
9 The Defendant will not suffer prejudice by the Court granting Plaintiff's Motion for
Extension of Time to respond to Defendant’s Discovery request.
WHEREFORE, based off of the foregoing, Plaintiff(s) requests that this Court grant
Plaintiff's Motion for Extension of Time to File Responses to Defendant’s Discovery Request(s).
Respectfully submitted to this Honorable Court on October 21, 2020.
/s/Steven Croskey, Esq.
SETZLER, CROSKEY, OWENS &
BONDARYK, ATTORNEYS AT LAW
Steven M. Croskey, Esq.
Florida Bar No.: 0102571
1644 Blanding Blvd.,
Jacksonville, FL 32210
Telephone: (904) 515-2187
Email: steven@croskeylaw.org
Attorney for Plaintiff(s)
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing document has been furnished on
October 21, 2020 to John Viggiani, Esq. and Ester K. Erkan, Esq., Conroy Simberg, via e-service
at eservicejax@conroysimberg.com; jviggiani@conroysimberg.com;
eerkan@conroysimberg.com.
/s/Steven Croskey, Esq.
SETZLER, CROSKEY, OWENS & BONDARYK
ATTORNEYS AT LAW
Steven M. Croskey, Esq.
Florida Bar No.: 0102571
1644 Blanding Blvd.,
Jacksonville, FL 32210
Telephone: (904) 515-2187
Email: steven@croskeylaw.org
Attorney for Plaintiff(s)
Document Filed Date
October 21, 2020
Case Filing Date
April 07, 2020
Category
Contract and Indebtedness Division: CV-D
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Filing # 115405143 E-Filed 10/21/2020 06:23:58 PM IN THE CIRCUIT COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA INGRID VALENTINE, PLAINTIFF, CASE NO.: 16-2020-CA-002061-XXXX-MA vs. MAIN STREET AMERICA PROTECTION INSURANCE COMPANY; MAIN STREET AMERICA ASSURANCE COMPANY, DEFENDANTS. / PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO DEFENDANT’S SECOND DISCOVERY REQUESTS COMES NOW, the Plaintiff, Ingrid Valentine, (hereinafter “Plaintiff(s)”), by and through the undersigned Attorney, and files this Motion for Extension of Time to File Responses to Defendant’s Second Discovery Request(s). As grounds therefore and in support thereof, the Plaintiff(s) would state as follows: 1 This is an action for breach of contract and statutory duties, seeking damages which do exceed $30,000.00 exclusive of costs, interest, and attorneys’ fees. 2. The Plaintiff filed a Complaint against Defendant. 3 After having been served with said Complaint, the Defendant filed discovery requests directed towards Plaintiffs. 4 Plaintiff responded to Defendant’s initial discovery requests. 5 Defendant has taken the deposition of Plaintiff. 6 Defendant has also compounded a second set of discovery requests on Plaintiff. 7 Plaintiff is in need of additional time to respond to the second round of discovery requests propounded on Plaintiff by Defendant. ACCEPTED: DUVAL COUNTY, RONNIE FUSSELL, CLERK, 10/23/2020 07:54:42 AM. 8 This Motion is not made for the purposes of harassment or delay. 9 The Defendant will not suffer prejudice by the Court granting Plaintiff's Motion for Extension of Time to respond to Defendant’s Discovery request. WHEREFORE, based off of the foregoing, Plaintiff(s) requests that this Court grant Plaintiff's Motion for Extension of Time to File Responses to Defendant’s Discovery Request(s). Respectfully submitted to this Honorable Court on October 21, 2020. /s/Steven Croskey, Esq. SETZLER, CROSKEY, OWENS & BONDARYK, ATTORNEYS AT LAW Steven M. Croskey, Esq. Florida Bar No.: 0102571 1644 Blanding Blvd., Jacksonville, FL 32210 Telephone: (904) 515-2187 Email: steven@croskeylaw.org Attorney for Plaintiff(s) CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing document has been furnished on October 21, 2020 to John Viggiani, Esq. and Ester K. Erkan, Esq., Conroy Simberg, via e-service at eservicejax@conroysimberg.com; jviggiani@conroysimberg.com; eerkan@conroysimberg.com. /s/Steven Croskey, Esq. SETZLER, CROSKEY, OWENS & BONDARYK ATTORNEYS AT LAW Steven M. Croskey, Esq. Florida Bar No.: 0102571 1644 Blanding Blvd., Jacksonville, FL 32210 Telephone: (904) 515-2187 Email: steven@croskeylaw.org Attorney for Plaintiff(s)