Motion,Ex Parte: Leanne Mastej v. Joseph Ryne, United Farm Family Mutual Insurance Company

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                                Filed: 8/31/2023 12:42 PM
                                                                                                                    Clerk
                                                                                                   Allen County, Indiana
                                                                                                                      ED



STATE OF INDIANA                      )       IN THE ALLEN SUPERIOR COURT NO. 1
                                      ) SS:
COUNTY OF ALLEN                       )       CAUSE NO. 02D01-2307-CT-000515

LEANNE MASTEJ,                                        )
                                                      )
               Plaintiff,                             )
                                                      )
v.                                                    )
                                                      )
JOSEPH RYNE AND UNITED FARM                           )
FAMILY MUTUAL INSURANCE                               )
COMPANY,                                              )
                                                      )
               Defendants.                            )

                   UNOPPOSED MOTION FOR EXTENSION OF TIME
                     TO RESPOND TO PLAINTIFF’S COMPLAINT

       This Defendant, Joseph Ryne, by counsel, respectfully requests the Court for an extension

of time of thirty (30) days in which to answer or otherwise respond to Plaintiff’s Complaint, and

in support would show the Court as follows:

       1.      That Plaintiff’s Complaint was filed with this Court on or about July 21, 2023.

       2.      That undersigned counsel requests additional time to enable counsel to confer with

               his client, to review the facts, and to prepare appropriate responses.

       3.      That the extension of time is not for purposes of delay and will not prejudice the

               Plaintiff.

       4.      That undersigned counsel has contacted counsel for Plaintiff and counsel for

               Plaintiff has voiced no objection to the requested extension.

       WHEREFORE, Defendant, Joseph Ryne, respectfully requests this Court for an

additional thirty (30) days in which to answer, or otherwise respond, to Plaintiff’s Complaint up

to, and including October 8, 2023, and for all other relief just and proper in the premises.
Respectfully submitted,

KOPKA PINKUS DOLIN PC


By: /s/ Orfej P. Najdeski
    Orfej P. Najdeski, Atty No. 21757-02
   Attorney for Defendant Joseph Ryne
                               CERTIFICATE OF SERVICE

        I hereby certify that on August 31, 2023, I electronically filed the foregoing document
using the Indiana eFiling System (IEFS). I further certify that the following persons were served
on the same date using the IEFS:

       Nathan D. Foushee
       nathanf@kennunn.com

       Daniel J. Palmer
       dpalmer@hsk-law.com



                                            /s/ Orfej P. Najdeski

KOPKA PINKUS DOLIN PC
11711 N. Meridian Street, Suite 350
Carmel, IN 46032
(317) 818-1360 | office
(317) 818-1390 | fax
opnajdeski@kopkalaw.com