On February 15, 2024 a
Party Discovery
was filed
involving a dispute between
Grappin Clinic Of Chiropractic Pa,
and
Progressive Select Insurance Company,
for SMALL CLAIMS BETWEEN $100-$500
in the District Court of Sarasota County.
Preview
Filing # 154766106 E-Filed 08/05/2022 12:03:41 PM
GRAPPIN CLINIC OF CHIROPRACTIC, P.A. IN THE COUNTY COURT OF THE 11TH
a/a/o LISA WILLIAMSON, JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
Plaintiff,
vs.
CASE NO: 2022-014501-SP-26
PROGRESSIVE SELECT INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S MOTION FOR LEAVE TO SERVE ADDITIONAL
INTERROGATORIES REQUESTS
COMES NOW Plaintiff through their undersigned counsel and pursuant to Fla.R.Civ.P.
1.340 files this Motion for Leave to Serve Additional Interrogatories and as grounds therefore
states as follows:
1. Plaintiff has already served interrogatories to Defendant. Upon information and belief,
it is believed that Plaintiff has or will serve supplemental interrogatories which exceed 30 as
permitted by Fla.R.Civ.P. 1.340.
2. Therefore, in effort to resolve this case on the merits and to eliminate unnecessary
proof, Plaintiff seeks leave to serve the additional interrogatories which are directly related to
the issues in this case. The Court has both explicit and inherent authority to permit service of
additional interrogatories requests under Florida law.
3. Defendant will not suffer any prejudice in granting such relief to the Plaintiff.
4. Plaintiff moves for relief in good faith to resolve this suit on the merits, and not for the
purpose of delay or otherwise. Plaintiff has or will make a good faith effort to resolve this issue
without a hearing.
WHEREFORE, Plaintiff respectfully requests that this Court grant leave to serve
additional interrogatories, as is reasonable under the circumstances, and grant all other and
further relief this Court deems just and proper.
Filed 02/15/2024 05:28 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
EMail on August 5, 2022 to Andres Millon, Esq., with Progressive PIP House Counsel, at
FLPIPHC-Miami@Progressive.com.
REIFKIND, THOMPSON & RUDZINSKI, LLP
Attorneys for Plaintiff
3333 W. Commercial Blvd., Suite 200B
Ft. Lauderdale, FL 33309
Office: (954) 370-5152
Fax: (954) 370-1992
Service E-mail: PipService@rtrlaw.com
By: /s/ Gregory Blackburn
Gregory Blackburn, Esq.
Florida Bar No. 15918
Document Filed Date
February 15, 2024
Case Filing Date
February 15, 2024
Category
SMALL CLAIMS BETWEEN $100-$500
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 154766106 E-Filed 08/05/2022 12:03:41 PM GRAPPIN CLINIC OF CHIROPRACTIC, P.A. IN THE COUNTY COURT OF THE 11TH a/a/o LISA WILLIAMSON, JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA Plaintiff, vs. CASE NO: 2022-014501-SP-26 PROGRESSIVE SELECT INSURANCE COMPANY, Defendant. / PLAINTIFF’S MOTION FOR LEAVE TO SERVE ADDITIONAL INTERROGATORIES REQUESTS COMES NOW Plaintiff through their undersigned counsel and pursuant to Fla.R.Civ.P. 1.340 files this Motion for Leave to Serve Additional Interrogatories and as grounds therefore states as follows: 1. Plaintiff has already served interrogatories to Defendant. Upon information and belief, it is believed that Plaintiff has or will serve supplemental interrogatories which exceed 30 as permitted by Fla.R.Civ.P. 1.340. 2. Therefore, in effort to resolve this case on the merits and to eliminate unnecessary proof, Plaintiff seeks leave to serve the additional interrogatories which are directly related to the issues in this case. The Court has both explicit and inherent authority to permit service of additional interrogatories requests under Florida law. 3. Defendant will not suffer any prejudice in granting such relief to the Plaintiff. 4. Plaintiff moves for relief in good faith to resolve this suit on the merits, and not for the purpose of delay or otherwise. Plaintiff has or will make a good faith effort to resolve this issue without a hearing. WHEREFORE, Plaintiff respectfully requests that this Court grant leave to serve additional interrogatories, as is reasonable under the circumstances, and grant all other and further relief this Court deems just and proper. Filed 02/15/2024 05:28 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via EMail on August 5, 2022 to Andres Millon, Esq., with Progressive PIP House Counsel, at FLPIPHC-Miami@Progressive.com. REIFKIND, THOMPSON & RUDZINSKI, LLP Attorneys for Plaintiff 3333 W. Commercial Blvd., Suite 200B Ft. Lauderdale, FL 33309 Office: (954) 370-5152 Fax: (954) 370-1992 Service E-mail: PipService@rtrlaw.com By: /s/ Gregory Blackburn Gregory Blackburn, Esq. Florida Bar No. 15918