Motion,Ex Parte: NEWBERRY CLINIC, P.A,USSERY, AMAYAS vs PERMANENT GENERAL ASSURANCE CORPORATION

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                Filing # 192999631 E-Filed 02/29/2024 10:37:27 AM


              IN THE COUNTY COURT IN AND FOR
              HILLSBOROUGH COUNTY, FLORIDA

              Case No.: 24-CC-005339 DIV J

              NEWBERRY CLINIC, P.A. A/A/O AMAYAS
              USSERY,

                              Plaintiff,

              v.

              PERMANENT GENERAL ASSURANCE
              CORPORATION,

                          Defendant.
              ____________________________________/

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


                     Defendant, PERMANENT GENERAL ASSURANCE CORPORATION (hereinafter

             referred to as “Defendant”), by and through the undersigned counsel and pursuant to the applicable

             Rules of Civil Procedure, hereby files its Motion for Extension of Time to file its Response to the

             Complaint filed by Plaintiff, NEWBERRY CLINIC, P.A. A/A/O AMAYAS USSERY,

             (hereinafter referred to as the “Plaintiff”), and in support thereof states as follows:



                     1.     The Complaint in this matter was served upon Defendant on or about February 26,

             2024.

                     2.     However, at this time, the undersigned counsel is not in a position to file its

             response to the Complaint, and as a result, seeks an additional extension of time to respond to

             same.




2/29/2024 10:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
                     3.     There should be no prejudice to any party by the granting of this enlargement of

             time.

                     4.     The undersigned will confer with counsel for Plaintiff prior to the date this motion

             is heard in an effort to reach an agreement as to the extension.

                     5.     This request is made in good faith, in an abundance of caution, and is not intended

             to delay action on this matter.


                     WHEREFORE,           Defendant,      PERMANENT             GENERAL         ASSURANCE

             CORPORATION, respectfully requests that this Court enter an Order granting this Motion for

             Extension of Time to Respond to the Complaint, and grant any further relief this Court deems just

             and proper under the circumstances.




                                         (Certificate of Service on following page)




                                                              2


2/29/2024 10:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
                                            CERTIFICATE OF SERVICE

                     I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by

             E-mail to: Gregory E. Gudin, Esq, efilings@pip-lawyers.com, on this 29th day of February,

             2024.




                                                                   KELLEY KRONENBERG


                                                                   /s/ Sam H. Itayim
                                                                   Sam H. Itayim, Esq.
                                                                   Fla. Bar No.: 0099803
                                                                   sitayim@kelleykronenberg.com
                                                                   10360 West State Road 84
                                                                   Fort Lauderdale, FL 33324
                                                                   Telephone: (954) 370-9970
                                                                   Facsimile: (954) 382-1988
                                                                   Attorneys for Defendant
                                                                   Address for service of pleadings only:
                                                                   shiservice@kelleykronenberg.com




                                                           3


2/29/2024 10:37 AM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3