On September 01, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Neurotech Family & Physical Medicine A A O Shirley Wright,
and
United Services Automobile Association,
for Small Claims $0-$99
in the District Court of Clay County.
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eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM
Filing # 137346873 E-Filed 10/27/2021 09:37:37 AM
IN THE COUNTY COURT IN AND FOR
CLAY COUNTY, FLORIDA
NEUROTECH FAMILY & PHYSICAL Case No.: 2021SC002327
MEDICINE A/A/O SHIRLEY WRIGHT,
Claim No.: 14969587-24
Plaintiff,
vs.
UNITED SERVICES AUTOMOBILE
ASSOCIATION,
Defendant.
_____________________________/
MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY
COMES NOW the Defendant, UNITED SERVICES AUTOMOBILE
ASSOCIATION, by and through the undersigned counsel and files this its Motion for
Enlargement of Time to Respond to Discovery and as grounds therefore would state as follows:
1. The Plaintiff, NEUROTECH FAMILY & PHYSICAL MEDICINE A/A/O
SHIRLEY WRIGHT, has propounded a Request for Admissions and Request to Produce upon
this Defendant.
2. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, was
served with said discovery on September 27, 2021.
3. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, would
request additional time to adequately respond to said discovery.
4. This Motion for Enlargement of Time is not dilatory in nature, and there will be
no prejudice to the Plaintiff in the granting of this motion.
5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time
within which to respond to Plaintiff’s outstanding discovery.
eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM
6. The Defendant reserves its right to object to any of Plaintiff’s discovery based
upon work product, attorney-client or other applicable privilege, protection or immunity from
discovery and specifically reserves its right to subsequently raise same.
WHEREFORE, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION,
respectfully requests this Honorable Court grant this Motion for Extension of Time to Respond
to Discovery for the reasons set forth above.
Page 2 of 3
Case No.: 2021SC002327
eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
E-Mail this 27th day of October 2021 to the following:
Julia E. Gazecka, Esq.
Shuster & Saben, LLC
10245 Centurion Parkway, Suite 305
Jacksonville, Florida 32256 at:
shustersabenjax@gmail.com
jaxpleadings@piplaw.com
ROIG LAWYERS
7380 Sand Lake Road, Suite 600
Orlando, FL 32819
(407) 349-6100 / (407) 349-6007 Fax
Pleadings@RoigLawyers.com
BY: /s/ Bartlett W. Lewis
BARTLETT W. LEWIS, ESQ.
Florida Bar No. 1008522
Page 3 of 3
Case No.: 2021SC002327
Document Filed Date
October 27, 2021
Case Filing Date
September 01, 2021
Category
Small Claims $0-$99
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eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM Filing # 137346873 E-Filed 10/27/2021 09:37:37 AM IN THE COUNTY COURT IN AND FOR CLAY COUNTY, FLORIDA NEUROTECH FAMILY & PHYSICAL Case No.: 2021SC002327 MEDICINE A/A/O SHIRLEY WRIGHT, Claim No.: 14969587-24 Plaintiff, vs. UNITED SERVICES AUTOMOBILE ASSOCIATION, Defendant. _____________________________/ MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY COMES NOW the Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, by and through the undersigned counsel and files this its Motion for Enlargement of Time to Respond to Discovery and as grounds therefore would state as follows: 1. The Plaintiff, NEUROTECH FAMILY & PHYSICAL MEDICINE A/A/O SHIRLEY WRIGHT, has propounded a Request for Admissions and Request to Produce upon this Defendant. 2. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, was served with said discovery on September 27, 2021. 3. Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, would request additional time to adequately respond to said discovery. 4. This Motion for Enlargement of Time is not dilatory in nature, and there will be no prejudice to the Plaintiff in the granting of this motion. 5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time within which to respond to Plaintiff’s outstanding discovery. eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM 6. The Defendant reserves its right to object to any of Plaintiff’s discovery based upon work product, attorney-client or other applicable privilege, protection or immunity from discovery and specifically reserves its right to subsequently raise same. WHEREFORE, Defendant, UNITED SERVICES AUTOMOBILE ASSOCIATION, respectfully requests this Honorable Court grant this Motion for Extension of Time to Respond to Discovery for the reasons set forth above. Page 2 of 3 Case No.: 2021SC002327 eFiled Date: 10/27/2021, Accepted: 10/27/2021 09:38 AM CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-Mail this 27th day of October 2021 to the following: Julia E. Gazecka, Esq. Shuster & Saben, LLC 10245 Centurion Parkway, Suite 305 Jacksonville, Florida 32256 at: shustersabenjax@gmail.com jaxpleadings@piplaw.com ROIG LAWYERS 7380 Sand Lake Road, Suite 600 Orlando, FL 32819 (407) 349-6100 / (407) 349-6007 Fax Pleadings@RoigLawyers.com BY: /s/ Bartlett W. Lewis BARTLETT W. LEWIS, ESQ. Florida Bar No. 1008522 Page 3 of 3 Case No.: 2021SC002327