Document for MASSEY CONSTRUCTION GROUP, INC vs. AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA

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                                Filing # 107644784 E-Filed 05/18/2020 07:01:55 PM


          IN THE CIRCUIT COURT OF THE 207?
          JUDICIAL CIRCUIT IN AND FOR
          CHARLOTTE COUNTY, FLORIDA

          CASE NO.:              20-000315-CA

          MASSEY               CONSTRUCTION               GROUP,        INC,
          a/aio MARGARET                  PUCKETT and
          MAX PUCKETT,

                         Plaintiff,

          V.

          AMERICAN INTEGRITY INSURANCE
          COMPANY OF FLORIDA,

                         Defendant.
                                                                             /

                                      DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
                                            RESPOND TO PLAINTIFF’S COMPLAINT

                    The Defendant,           AMERICAN          INTEGRITY              INSURANCE COMPANY                  OF FLORIDA

        (hereinafter          referred    to as “Defendant”),        pursuant        to the applicable     Rules    of Civil   Procedure,

        hereby       files     its Motion     for Extension        of Time       to file   its Response    to the Complaint      filed    by

        Plamtiff,         MASSEY CONSTRUCTION                       GROUP,          INC, a/a/o MARGARET               PUCKETT       and

        MAX         PUCKETT              (hereinafter   referred    to as the “Plaintiff’),          and in support thereof states as

         follows:

                    1             The Complaint in this matter was served upon Defendant on April 27, 2020.

                    2.            However,     at this time,       the undersigned         counsel    is not in a position     to file    its

        response to the Complaint,                and as a     result, seeks an additional           extension     of time to respond to

        same.


                    3             There should be no prejudice to any party by the granting of this enlargement                           of

        time.


                    4             The undersigned will confer with counsel for Plaintiff prior to the date this motion

         is heard in an effort to reach an agreement as to the extension.
Case No.; 20-000315-CA


          5       This is Defendant’s first Motion for Extension of time to respond to the Complaint,

and is made in good faith,      in an abundance    of caution,    and is not intended to delay action in this

matter.


          WHEREFORE,       Defendant,   AMERICAN          INTEGRITY        INSURANCE        COMPANY       OF

FLORIDA, respectfully requests that this Court enter an Order granting this Motion for Extension

of Time to Respond to the Complaint,         and grant any further relief this Court deems just and proper

under the circumstances.


                                     CERTIFICATE          _OF SERVICE

          THEREBY CERTIFY that a true and correct copy of the foregoing was sent via electronic

mail on May 18, 2020 to Alex Finch, Esq., Counsel for Plaintiff, Fromang & Finch, PA, P.O. Box

915096,       Longwood,    FL   32791   at    alex@fromangfinch.com;         afinchlegal@ gmail.com.     This

document is being served on all counsel and pro se parties of record by the Florida Courts E-Filing

Portal, pursuant to and in compliance with Fla. R. Jud. Admin. 2.516


                                                        KELLEY        KRONENBERG
                                                        Counsel for Defendant
                                                        10360 W. State Road 84
                                                        Fort Lauderdale, FL 33324
                                                        Telephone: (954) 370-9970
                                                        Facsimile:     (954) 382-1988

                                                        BY: 4/Lizhell R. Lucero
                                                            LIZBELL R. LUCERO, ESQ.
                                                            Florida Bar No. 125063
                                                            ALEXANDER D. KOCHMAN, ESQ.
                                                            Florida Bar No. 104764
                                                            AKochman@kelleykronenberg.com
                                                            LLucero@kelleykronenberg.com
                                                                 MParedes@kelleykronenberg.com