On March 06, 2024 a
Motion,Ex Parte
was filed
involving a dispute between
Crews, Gina A,
Crews, Robert C,
and
Nationwide Mutual Insurance Co,
for CONTRACTS AND INDEBTEDNESS
in the District Court of Columbia County.
Preview
Filing # 195029973 E-Filed 03/28/2024 01:35:06 PM
IN THE CIRCUIT COURT OF THE 3"? JUDICIAL CIRCUIT
IN AND FOR COLUMBIA COUNTY, FLORIDA
CASE NO: 24-000083-CA-AXMS
ROBERT C. CREWS
AND GINA A. CREWS,
PLAINTIFF
Vv.
NATIONWIDE MUTUAL
INSURANCE COMPANY,
DEFENDANT.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFFS’ COMPLAINT
COMES NOW Defendant, by and through undersigned counsel, and pursuant to Florida
Rule of Civil Procedure 1.090(b), respectfully requests that this Court grant an extension of time
to allow Defendant to respond to Plaintiffs’ Complaint and as grounds therefore states as follows:
1 Defendant was served with the present Complaint on March 8, 2024. Accrodingly,
Defendant’s response to Plaintiffs’ Complaint is due today March 28, 2024.
2 However, Defendant is in the process of reviewing the allegations set forth in
Plaintiffs’ Complaint as well as its file to properly frame its response to Plaintiffs’ Complaint.
3 Asa result, Defendant requires additional time to respond to Plaintiffs’ Complaint.
4 Pursuant to Florida Rule of Civil Procedure 1.090(b):
(b) Enlargement. When an act is required or allowed to be done at or
within a specified time by order of court, by these rules, or by notice
given thereunder, for cause shown the court at any time in its
discretion (1) with or without notice, may order the period enlarged
if request therefor is made before the expiration of the period
originally prescribed or as extended by a previous order, or (2) upon
motion made and notice after the expiration of the specified period,
may permit the act to be done when failure to act was the result of
Electronically Filed Columbia Case # 24000083CAAXMX 03/28/2024 01:35:06 PM
excusable neglect , but it may not extend the time for making a motion
for new trial, for rehearing, or to alter or amend a judgment; making
a motion for relief from a judgment under rule 1.540(b); taking an
appeal or filing a petition for certiorari; or making a motion for a
directed verdict.
This motion is made in good faith and not for the purposes of delay.
The Plaintiffs will not be prejudiced by the requested extension of time.
7
This is matter is not set for trial.
8 Defendant has or will confer with Plaintiffs in a good faith attempt to resolve the
extension of time requested herein.
WHEREFORE, Defendant, respectfully requests a 30 days extension of time to respond to
Plaintiffs’ Complaint and for such other relief this Court deems just and proper.
CERTIFICATE OF SERVICE
The document contains no confidential or sensitive information or that any such
confidential or sensitive language has been properly protected by complying with the provisions
of Rule 2.420 and 2.425. [HEREBY CERTIFY that a true and correct copy of the foregoing has
been furnished by electronic filing to atty. Mohad Abbass at eservice@talktomyattorneys.com,
and mabbass@talktomyattorneys.com, on this 28" day of March, 2024.
/s/ Pedro M. Ortiz
PEDRO M. ORTIZ, ESQUIRE
Fla. Bar No.: 12075
Law Office of Jennifer Forte
200 East Robinson Street, Suite 510
Orlando, FL 32801
Direct Dial: (305)505-4506
Paralegal: (407) 393-9410
Primary: ORLMAIL@nationwide.com
Secondary: ortizp2@nationwide.com
fernad2@nationwide.com
Attorneys for Defendant
Document Filed Date
March 28, 2024
Case Filing Date
March 06, 2024
Category
CONTRACTS AND INDEBTEDNESS
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Filing # 195029973 E-Filed 03/28/2024 01:35:06 PM IN THE CIRCUIT COURT OF THE 3"? JUDICIAL CIRCUIT IN AND FOR COLUMBIA COUNTY, FLORIDA CASE NO: 24-000083-CA-AXMS ROBERT C. CREWS AND GINA A. CREWS, PLAINTIFF Vv. NATIONWIDE MUTUAL INSURANCE COMPANY, DEFENDANT. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT COMES NOW Defendant, by and through undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.090(b), respectfully requests that this Court grant an extension of time to allow Defendant to respond to Plaintiffs’ Complaint and as grounds therefore states as follows: 1 Defendant was served with the present Complaint on March 8, 2024. Accrodingly, Defendant’s response to Plaintiffs’ Complaint is due today March 28, 2024. 2 However, Defendant is in the process of reviewing the allegations set forth in Plaintiffs’ Complaint as well as its file to properly frame its response to Plaintiffs’ Complaint. 3 Asa result, Defendant requires additional time to respond to Plaintiffs’ Complaint. 4 Pursuant to Florida Rule of Civil Procedure 1.090(b): (b) Enlargement. When an act is required or allowed to be done at or within a specified time by order of court, by these rules, or by notice given thereunder, for cause shown the court at any time in its discretion (1) with or without notice, may order the period enlarged if request therefor is made before the expiration of the period originally prescribed or as extended by a previous order, or (2) upon motion made and notice after the expiration of the specified period, may permit the act to be done when failure to act was the result of Electronically Filed Columbia Case # 24000083CAAXMX 03/28/2024 01:35:06 PM excusable neglect , but it may not extend the time for making a motion for new trial, for rehearing, or to alter or amend a judgment; making a motion for relief from a judgment under rule 1.540(b); taking an appeal or filing a petition for certiorari; or making a motion for a directed verdict. This motion is made in good faith and not for the purposes of delay. The Plaintiffs will not be prejudiced by the requested extension of time. 7 This is matter is not set for trial. 8 Defendant has or will confer with Plaintiffs in a good faith attempt to resolve the extension of time requested herein. WHEREFORE, Defendant, respectfully requests a 30 days extension of time to respond to Plaintiffs’ Complaint and for such other relief this Court deems just and proper. CERTIFICATE OF SERVICE The document contains no confidential or sensitive information or that any such confidential or sensitive language has been properly protected by complying with the provisions of Rule 2.420 and 2.425. [HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic filing to atty. Mohad Abbass at eservice@talktomyattorneys.com, and mabbass@talktomyattorneys.com, on this 28" day of March, 2024. /s/ Pedro M. Ortiz PEDRO M. ORTIZ, ESQUIRE Fla. Bar No.: 12075 Law Office of Jennifer Forte 200 East Robinson Street, Suite 510 Orlando, FL 32801 Direct Dial: (305)505-4506 Paralegal: (407) 393-9410 Primary: ORLMAIL@nationwide.com Secondary: ortizp2@nationwide.com fernad2@nationwide.com Attorneys for Defendant