Document for MOHR, DENNIS E vs. AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA

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                                Filing # 176150266 E-Filed 06/26/2023 03:57:00 PM




         IN THE CIRCUIT COURT OF THE 20th
         JUDICIAL  CIRCUIT  IN  AND  FOR
         CHARLOTTE COUNTY, FLORIDA

         Case No.:   23001809CA

         DENNIS E. MOHR AND HEIDI R. MOHR,,

                         Plaintiffs,

         Vv.


         AMERICAN INTEGRITY INSURANCE
         COMPANY OF FLORIDA,

                         Defendant.
                                                       /

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

                Defendant,    AMERICAN       INTEGRITY     INSURANCE          COMPANY     OF    FLORIDA

        (hereinafter referred to as “Defendant”), by and through the undersigned counsel and hereby files

         its Motion for Extension of Time to Respond to the discovery requests that Plaintiffs, DENNIS E.

        MOHR AND HEIDI R. MORR (hereinafter referred to as the “Plaintiffs”), propounded with the

        Complaint, and in support states as follows:

                1      On May 12, 2023, Defendant was served the Complaint in the present matter, along

        with Plaintiffs’ Request for Admissions and Request for Production.

                2      Due to the press of business, the undersigned is requesting an extension of time to

        respond to Plaintiffs’ discovery requests.

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

        within which to respond to the aforementioned discovery requests.
CASE NO.: 20001809CA.


          4          Undersigned      counsel will confer with Plaintiffs' counsel prior to the date this

motion is heard in an effort to reach an agreement to the extension.

          5          This is Defendant’s first request for extension of time to respond to discovery and

said request 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 Plaintiff's Request for Admissions                    and Plaintiff's First Request        for

Production, and grant any further relief this Court deems just and proper under the circumstances.


                                          CERTIFICATE          OF SERVICE

          I HEREBY        CERTIFY that on 26 day of June, 2023, this document was filed using the

Florida Courts E-Filing Portal.           This document is being served on all counsel of record by the

Florida Courts Efiling Portal, pursuant to and in compliance with Fla. R. Jud. Admin. 2.516.                          The

addresses       of    counsel      are:   Scott     J    Forster,     Esquire,      Kanner    &      Pinataluga,     P.A,
FirstPartyEService@kpattorney.com,                925   S. Federal Hwy.,         6th Floor, Boca    Raton,   FL    33432,

(561) 424-0032/(866) 641-4690 (F), Attorney for Plaintiff, Dennis E. Mohr.

                                                              Kelley Kronenberg
                                                              is/ Rabat S. DiMaro
                                                              Robert S. DiMarco, Esquire
                                                              Fla. Bar No. 1025823
                                                              10360 West State Road 84
                                                              Fort Lauderdale, FL        33324
                                                              Telephone: (954) 370-9970
                                                              Counsel for Defendant
                                                              SERVICE EMAIL:
                                                              rdimarco@kelleykronenberg.com