Motion,Ex Parte: Jakelin L. Aguigure v. Danika R. Smith, Pace Air Freight, Inc.

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                                Filed: 9/21/2023 1:56 PM
                                                                                             Boone Superior Court 1
                                                                                              Boone County, Indiana




STATE OF INDIANA              )                      IN THE BOONE SUPERIOR COURT
                              ) SS:
COUNTY OF BOONE               )                      CAUSE NO. 06D01-2308-CT-001152

JAKELIN L. AGUIGURE,                         )
                                             )
                      Plaintiff,             )
v.                                           )
                                             )
DANIKA R. SMITH,                             )
PACE AIR FREIGHT, INC., and                  )
AMERICAN ACCESS                              )
CASUALTY COMPANY,                            )
                                             )
                      Defendants.            )


                           MOTION FOR EXTENSION OF TIME

       Comes now the Defendant, American Access Casualty Company, by counsel, and

respectfully moves the court for an extension of time to and including October 23, 2023, within

which to file an answer to Plaintiff's Complaint, and in support thereof would represent and show

the court the following:

       l.      That said Defendant's response is presently due.

       2.      That no prior extensions have been requested.

       3.      That Defendant's counsel has just been retained to represent said Defendant in the

above cause and will need an extension of time to and including October 23, 2023, within which

to confer with his client, and be in a position to file a proper response for and on behalf of this

Defendant.

       WHEREFORE, the Defendant prays for an extension of time to and including October 23,

2023, within which to respond to Plaintiff's Complaint.
                                                    Respectfully submitted,

                                                    METZGER ROSTA LLP



                                             By:
                                                    Thomas E. Rosta (#18858-45)
                                                    Attorney for Defendant,
                                                    American Access Casualty Company


                                CERTIFICATE OF SERVICE

       I hereby certify that on the 21st day of September, 2023, pursuant to Rule 86(G) of the

Indiana Rules of Trial Procedure, the foregoing document was electronically filed using the IEFS.

I certify that the following persons were electronically served with the foregoing document:

David E. Jacuk
Darron S. Stewart
Stewart & Stewart
931 South Rangeline Road
Carmel, IN 46032
david@getstewart.com
darron@getstewart.com




                                                    Thomas E. Rosta (#18858-45)

METZGER ROSTA LLP
32 S. 9th Street
Noblesville, IN 46060
(317) 219-4606
tom@metzgerrosta.com