On March 23, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Vanessa Singleton,
and
Direct General Insurance Company,
Kevin K Lewis,
Zereeda V Lewis,
in the District Court of Duval County.
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Filing # 177420645 E-Filed 07/14/2023 10:58:07 AM
IN THE CIRCUIT COURT OF THE 4th
JUDICIAL CIRCUIT, IN AND FOR DUVAL
COUNTY, FLORIDA
CASE NO: 2023-CA-006648
VANESSA SINGLETON,
Plaintiff,
vs.
ZEREEDA V. LEWIS, KEVIN K. LEWIS AND
DIRECT GENERAL INSURANCE COMPANY,
Defendant.
__________________________________/
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW the Defendant, DIRECT GENERAL INSURANCE COMPANY, by and
through their undersigned counsel files their Motion for Enlargement of Time to respond to
Plaintiff’s Complaint and as grounds therefore states as follows:
1. This motion is not filed for the purposes of delay.
2. This matter is premature and is not currently set for trial and shall not prejudice
the Plaintiff.
3. The Defendant was served with the Summons and Complaint via the Chief
Financial Officer of the State of Florida on June 26, 2023.
4. Undersigned counsel is waiting to receive certain information from the Defendant
in order to respond to this Complaint.
5. Pursuant to F. R. Civ. P. 1.090 entitled “Time,” states, in pertinent part:
(b) Enlargement. --When an act is required or allowed to be done at or
within a specified time by order of court, by these rules, or by notice given
thereunder, for cause shown the court at any time in its discretion (1) with
or without notice, may order the period enlarged if request therefore is
made before the expiration of the period originally prescribed or as
extended by a previous order (emphasis added)
6. This motion is being filed before the deadlines imposed by the above
stated F. R. Civ. P. and is therefore timely.
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/17/2023 04:38:07 PM
7. Since this litigation is in its preliminary stages, such an extension will not be
prejudicial to the Plaintiff.
8. This motion is being made in good faith and not to hinder or delay these
proceedings.
WHEREFORE the undersigned counsel seeks an enlargement of time to respond to
Plaintiff’s Complaint, along with any and all such further relief as this court deems necessary
and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
electronic mail to: dwolf@woodatter.com and erikac@woodatter.com; David A. Wolf, Esq.;
Wood, Atter & Wolf, P.A., 100 N. Laura Street, Suite 702, Jacksonville, FL 32202 on this 14th
day of July, 2023.
McFARLANE LAW
McFarlane Dolan & Prince
Attorneys for Defendant
210 N. University Drive, 6th Floor
Coral Springs, Florida 33071
(954) 340-0005 Broward
(954) 340-0055 Facsimile
PLEADING SERVICE E-MAIL ADDRESS:
pleadingservice@mcfarlanedolanlaw.com
By: /s/ William J. McFarlane, III, Esquire
WILLIAM J. McFARLANE, ESQUIRE
Florida Bar No: 768601
Document Filed Date
July 14, 2023
Case Filing Date
March 23, 2023
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Filing # 177420645 E-Filed 07/14/2023 10:58:07 AM IN THE CIRCUIT COURT OF THE 4th JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA CASE NO: 2023-CA-006648 VANESSA SINGLETON, Plaintiff, vs. ZEREEDA V. LEWIS, KEVIN K. LEWIS AND DIRECT GENERAL INSURANCE COMPANY, Defendant. __________________________________/ DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW the Defendant, DIRECT GENERAL INSURANCE COMPANY, by and through their undersigned counsel files their Motion for Enlargement of Time to respond to Plaintiff’s Complaint and as grounds therefore states as follows: 1. This motion is not filed for the purposes of delay. 2. This matter is premature and is not currently set for trial and shall not prejudice the Plaintiff. 3. The Defendant was served with the Summons and Complaint via the Chief Financial Officer of the State of Florida on June 26, 2023. 4. Undersigned counsel is waiting to receive certain information from the Defendant in order to respond to this Complaint. 5. Pursuant to F. R. Civ. P. 1.090 entitled “Time,” states, in pertinent part: (b) Enlargement. --When an act is required or allowed to be done at or within a specified time by order of court, by these rules, or by notice given thereunder, for cause shown the court at any time in its discretion (1) with or without notice, may order the period enlarged if request therefore is made before the expiration of the period originally prescribed or as extended by a previous order (emphasis added) 6. This motion is being filed before the deadlines imposed by the above stated F. R. Civ. P. and is therefore timely. ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 07/17/2023 04:38:07 PM 7. Since this litigation is in its preliminary stages, such an extension will not be prejudicial to the Plaintiff. 8. This motion is being made in good faith and not to hinder or delay these proceedings. WHEREFORE the undersigned counsel seeks an enlargement of time to respond to Plaintiff’s Complaint, along with any and all such further relief as this court deems necessary and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by electronic mail to: dwolf@woodatter.com and erikac@woodatter.com; David A. Wolf, Esq.; Wood, Atter & Wolf, P.A., 100 N. Laura Street, Suite 702, Jacksonville, FL 32202 on this 14th day of July, 2023. McFARLANE LAW McFarlane Dolan & Prince Attorneys for Defendant 210 N. University Drive, 6th Floor Coral Springs, Florida 33071 (954) 340-0005 Broward (954) 340-0055 Facsimile PLEADING SERVICE E-MAIL ADDRESS: pleadingservice@mcfarlanedolanlaw.com By: /s/ William J. McFarlane, III, Esquire WILLIAM J. McFARLANE, ESQUIRE Florida Bar No: 768601