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

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                                Filed: 9/27/2023 4:30 PM
                                                                                           Boone Superior Court 1
                                                                                            Boone County, Indiana




STATE OF INDIANA                      )       BOONE COUNTY SUPERIOR COURT 1
                                      ) 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.                    )

        DEFENDANTS’, DANIKA R. SMITH AND PACE AIR FREIGHT, INC.’S
           MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
                 PLAINTIFF’S COMPLAINT FOR DAMAGES

       Defendants, Danika R. Smith and Pace Air Freight, Inc. (“Defendants”), by counsel,

Houston A. Hum of Reminger Co., LPA, respectfully move the Court for a thirty day enlargement

of time up to and including October 30, 2023 in which to answer or otherwise plead in response to

Plaintiff’s Complaint for Damages. In support thereof, Defendants state as follows:

       1.      Plaintiff’s Complaint for Damages was filed with this Court on August 27, 2023.

       2.      Defendant, Pace Air Freight, Inc., was served with the Summons and Complaint

via certified mail on September 5, 2023. Defendant, Danika R. Smith, has not yet been served.

       3.      Defendants respectfully requests an enlargement of time to and including October

28 to file a responsive pleading to Plaintiff’s Complaint.

       4.      This motion is made in good faith and not for the purpose of hindrance or delay,

but to allow Defendants appropriate and reasonable time to investigate and respond to the

allegations contained in the Plaintiff’s Complaint for Damages.

       5.      This motion, if granted, will not unduly prejudice any party.
       6.      On September 27, 2023, the undersigned counsel for Defendants attempted to

inquire with counsel for Plaintiff as to whether he opposed this Motion, but the undersigned was

unable to reach him.

       WHEREFORE, Defendants, Danika R. Smith and Pace Air Freight, Inc., hereby request

an extension to and including October 30, 2023, to file an answer or otherwise plead in response

to Plaintiff’s Complaint for Damages, and for all other just and proper relief.


                                              Respectfully submitted,


                                              /s/ Houston A. Hum
                                              Houston A. Hum (31352-49)
                                              REMINGER CO., LPA
                                              College Park Plaza
                                              8909 Purdue Road, Suite 200
                                              Indianapolis, IN 46268
                                              T: 317-663-8570 | F: 317-228-0943
                                              hhum@reminger.com
                                              Attorney for Defendants Danika R. Smith and
                                              Pace Air Freight, Inc.

                                 CERTIFICATE OF SERVICE

       I hereby certify that a true and accurate copy of the foregoing has been filed on this 27th

day of September, 2023 using the Indiana E-Filing System (IEFS) which will send notice to all

counsel of record.

                                              /s/ Houston A. Hum
                                              Houston A. Hum
                                              REMINGER CO., L.P.A.




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