On March 17, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Stabrylla, Stephanie,
and
Safeco Insurance Company Of Illinois,
Whitkopf, Elizabeth,
for Auto Negligence
in the District Court of Charlotte County.
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Filing # 194422439 E-Filed 03/20/2024 12:01:59 PM
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CASE NO.: 23000551CA
STEPHANIE STABRYLLA,
Plaintiff,
vs.
ELIZABETH WHITKOPF and
SAFECO INSURANCE COMPANY
OF ILLINOIS,
Defendants.
/
SUPPLEMENTAL MOTION TO CONTINUE TRIAL
The Defendant, ELIZABETH WHITKOPF, by and through the undersigned counsel, and
hereby files this Motion to Continue Trial, and as grounds states the following:
1 This is a personal injury case arising out of an automobile accident which occurred
on September 29, 2022. The defendant answered the Complaint on June 12, 2023,
and the general guidelines for trial to occur is usually eighteen months.
This action is currently scheduled for trial on this Court’s docket beginning May
13, 2024, through June 21, 2024. Discovery cutoff in this case is April 12, 2024.
Defendant’s counsel requires additional time in which to prepare this case for trial
as additional discovery may need to be conducted, Mediation is scheduled for
February 19, 2024, and Medical Examinations are pending to be completed and a
full accounting of Plaintiffs claimed damages needs to be conducted in order to
properly defend Plaintiff's claims.
CASE NO.: 23000551CA
The Defendant is entitled to conduct the necessary discovery in order to provide a
full and proper defense to the Plaintiff's claims for damages in this action.
Case is not ready for trial
Defendant ELIZABETH WHITKOPF is scheduled for an outpatient procedure on
May 15'* with at least a 2-week recovery time period and may not be available
during the trial period.
7 This Motion is filed in good faith and not for purposes of delay.
WHEREFORE, the Defendant. ELIZABETH WHITKOPF, hereby requests this
Honorable Court grant this Motion and enter an Order continuing the trial from the Court’s docket
commencing on May 13, 2024, for the reasons set forth above.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a copy of the foregoing has been furnished by email to: FRANK
P. DiPLACIDO, III, ESQ., Attorney for Plaintiff, at fdiplacido@forthepeople.com and
morganservice@forthepeople.com, on this 21% day of March 2024
HILL & LEMONGELLO, P.A.
Attorneys for Def - Whitkopf
800 Southeast 3rd Avenue, Suite 200
Fort Lauderdale, Florida 33316
954-462-3623 - main
954-523-1940- fax
ee -lem-law.com- Primary
Joant@ hitl-Tem-law.con
Danl@hill- Jem-! law.com\- Secondary
BY.
DAD EL LEMONGELLO
FLOR A BAR # 0027049
Document Filed Date
March 20, 2024
Case Filing Date
March 17, 2023
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Filing # 194422439 E-Filed 03/20/2024 12:01:59 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE NO.: 23000551CA STEPHANIE STABRYLLA, Plaintiff, vs. ELIZABETH WHITKOPF and SAFECO INSURANCE COMPANY OF ILLINOIS, Defendants. / SUPPLEMENTAL MOTION TO CONTINUE TRIAL The Defendant, ELIZABETH WHITKOPF, by and through the undersigned counsel, and hereby files this Motion to Continue Trial, and as grounds states the following: 1 This is a personal injury case arising out of an automobile accident which occurred on September 29, 2022. The defendant answered the Complaint on June 12, 2023, and the general guidelines for trial to occur is usually eighteen months. This action is currently scheduled for trial on this Court’s docket beginning May 13, 2024, through June 21, 2024. Discovery cutoff in this case is April 12, 2024. Defendant’s counsel requires additional time in which to prepare this case for trial as additional discovery may need to be conducted, Mediation is scheduled for February 19, 2024, and Medical Examinations are pending to be completed and a full accounting of Plaintiffs claimed damages needs to be conducted in order to properly defend Plaintiff's claims. CASE NO.: 23000551CA The Defendant is entitled to conduct the necessary discovery in order to provide a full and proper defense to the Plaintiff's claims for damages in this action. Case is not ready for trial Defendant ELIZABETH WHITKOPF is scheduled for an outpatient procedure on May 15'* with at least a 2-week recovery time period and may not be available during the trial period. 7 This Motion is filed in good faith and not for purposes of delay. WHEREFORE, the Defendant. ELIZABETH WHITKOPF, hereby requests this Honorable Court grant this Motion and enter an Order continuing the trial from the Court’s docket commencing on May 13, 2024, for the reasons set forth above. CERTIFICATE OF SERVICE THEREBY CERTIFY that a copy of the foregoing has been furnished by email to: FRANK P. DiPLACIDO, III, ESQ., Attorney for Plaintiff, at fdiplacido@forthepeople.com and morganservice@forthepeople.com, on this 21% day of March 2024 HILL & LEMONGELLO, P.A. Attorneys for Def - Whitkopf 800 Southeast 3rd Avenue, Suite 200 Fort Lauderdale, Florida 33316 954-462-3623 - main 954-523-1940- fax ee -lem-law.com- Primary Joant@ hitl-Tem-law.con Danl@hill- Jem-! law.com\- Secondary BY. DAD EL LEMONGELLO FLOR A BAR # 0027049