Document for Abayomi Manrique Plaintiff vs. Progressive American Insurance Company Defendant

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                                Filing # 125811440 E-Filed 04/28/2021 11:23:19 PM


                        IN THE COUNTY COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR
                                        BROWARD COUNTY, FLORIDA




        ABAYOMI MANRIQUE,                                                         CASE NO.: COWE21001213
                  Plaintiff,                                                      DIVISION: 82
        vs.

        PROGRESSIVE AMERICAN
        INSURANCE COMPANY, a
        Foreign Profit Corporation,
                  Defendant.
                                             /

                            PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO
                              RESPOND TO DEFENDANT’S DISCOVERY RE! UESTS
                  Comes now Plaintiff, ABAYOMI           MANRIQUE,       by and through undersigned counsel,
        pursuant to the Fla. R. Civ. P. 1.090(b) files their Motion for Enlargement of Time to Respond to
        Defendant’s Discovery Requests and states:

                    1       This is an auto insurance bad faith claim for the recovery of uninsured/underinsured
        motorists coverage benefits.

                  2.        On March 31‘, 2021, the Defendant propounded Interrogatories, Request for
        Production and Request for Admissions onto the Plaintiffs.

                  3         The Plaintiff needs additional time to respond to the Defendant’s          discovery
        requests.

                  4         The Court has discretion under Fla. R. Civ. P. 1.090(b) to enlarge time to respond:

        (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 therefor is
        made before the expiration of the period originally prescribed or as extended by a previous order,
        or (2) upon motion made and notice after the expiration of the specified period, may permit the act
        to be done when failure to act was the result of excusable neglect, but it may not extend the time
        for making a motion for new trial, for rehearing, or to alter or amend a judgment; making a motion




              #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN,             CLERK 04/28/2021 11:23:18 PM.**#*
for relief from a judgment under rule 1.540(b); taking an appeal or filing a petition for certiorari;
or making a motion for a directed verdict.

        5      This case is not currently on a trial docket       and there is no prejudice to the
Defendants by enlarging the time to respond to their discovery requests.

       WHEREFORE,         Plaintiff,   ABAYOMI     MANRIQUE,         respectfully    requests   that   their
Motion for Enlargement of Time to Respond to Defendant’s Discovery Requests be granted and
an Order be entered for the same.

                                    CERTIFICATE OF SERVICE
       I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the
Clerk of Court, Miami-Dade County, Florida using the Florida E-Filing Portal system and served
via e-service on Attorney for Defendant, Alexandra M. Taboada-McGill, Esq. of Law Offices of
Michael W. Carroll, 3230 West Commercial Boulevard, Suite 400, Fort Lauderdale, Florida 33309
at: ftlauderdalehc@progressive.com;      alexandra_m_taboada@progressive.com;           on 28", day of
April 2021.
                                                                       Charles Legal, PLLC
                                                                       Counsel for Plaintiffs
                                                                       930 South     State Road 7
                                                                       Plantation,    Florida 33317
                                                                       Tel: (954)    342-6446
                                                                       Fax: (954)    301-7700
                                                                       steve@charleslegalpl.com
                                                                By      [s] Steve Louis-Charles
                                                                        Steve Louis-Charles, Esq.
                                                                        Florida Bar No.: 98666