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Filing # 201885248 E-Filed 07/03/2024 01:48:33 PM
IN THE CIRCUIT COURT OF THE
13TH JUDICIAL CIRCUIT IN AND FOR
HILLSBOROUGH COUNTY, FLORIDA
TAMIKA FAULKNER,
Plaintiff,
vs. Case No. 24-CA-003323
ELEVANCE HEALTH INC f/k/a
THE ANTHEM COMPANIES INC.,
Defendant.
DEFENDANT’S CONSENT MOTION FOR AN EXTENSION OF TIME
TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT
Defendant Elevance Health, Inc. (“Elevance”), incorrectly identified as “Elevance Health
Inc. f/k/a The Anthem Companies, Inc.,” by its attorneys and pursuant to Fla. R. Civ. P. 1.090(b),
respectfully submits this Consent Motion for an Extension of Time to Answer or Otherwise
Respond to Plaintiff’s Complaint. As grounds for this motion, Elevance states as follows:
1. Plaintiff filed her Complaint on April 23, 2024.
2. Elevance was served with the Summons and Complaint on June 18, 2024 making
Elevance’s responsive pleading due on July 8, 2024.
3. Elevance and its counsel require additional time to fully investigate and respond to
Plaintiff’s allegations and claims.
4. Accordingly, Elevance seeks an extension of 21 days, through and including July
29, 2024, to answer or otherwise respond to Plaintiff’s Complaint.
5. Elevance’s counsel conferred with Plaintiff’s counsel regarding this motion, and
Plaintiff’s counsel consents to Elevance’s requested extension of time.
312213104v.1
7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1
6. This request is made in good faith and will not affect any other deadlines or the
just, speedy, and inexpensive determination of this action. This extension of time will allow
Elevance sufficient time to fully investigate the allegations and claims raised by Plaintiff’s
Complaint, confer with counsel, and prepare its response. This is Elevance’s first request for an
extension of time.
CERTIFICATE OF CONFERRAL
On July 2, 2024, counsel for Elevance conferred with Plaintiff’s counsel via email
regarding the requested enlargement of time. Plaintiff’s counsel confirmed that Plaintiff consents
to the relief requested herein.
WHEREFORE, Elevance respectfully requests that the Court grant this consent motion
and extend Elevance’s deadline to answer or otherwise respond to Plaintiff’s Complaint through
and including July 29, 2024.
Dated: July 3, 2024 Respectfully submitted,
SEYFARTH SHAW LLP
By: /s/ Alex S. Drummond
Alex S. Drummond
Florida Bar No. 038307
adrummond@seyfarth.com
SEYFARTH SHAW LLP
1075 Peachtree Street, N.E.
Suite 2500
Atlanta, Georgia 30309-3958
Telephone: (404) 885-1500
Facsimile: (404) 892-7056
Counsel for Defendant
Elevance Health, Inc.
2
312213104v.1
7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2
IN THE CIRCUIT COURT OF THE
13TH JUDICIAL CIRCUIT IN AND FOR
HILLSBOROUGH COUNTY, FLORIDA
TAMIKA FAULKNER,
Plaintiff,
vs. Case No. 24-CA-003323
ELEVANCE HEALTH INC f/k/a
THE ANTHEM COMPANIES INC.,
Defendant.
CERTIFICATE OF SERVICE
I hereby certify that on July 3, 2024, I electronically filed this CONSENT MOTION FOR
AN EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO
PLAINTIFF’S COMPLAINT with the Clerk of Court via the Florida e-Filing Portal, which will
automatically send e-mail notification of such filing to all counsel of record, including:
Anthony M. Georges-Pierre, Esq.
agp@rgph.law
REMER, GEORGES-PIERRE & HOOGERWOERD, PLLC
2745 Ponce De Leon Boulevard
Coral Gables, Florida 33134
By: /s/ Alex S. Drummond________
Alex. S. Drummond
Counsel For Defendant
Elevance Health, Inc.
3
312213104v.1
7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3
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Filing # 201885248 E-Filed 07/03/2024 01:48:33 PM IN THE CIRCUIT COURT OF THE 13TH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA TAMIKA FAULKNER, Plaintiff, vs. Case No. 24-CA-003323 ELEVANCE HEALTH INC f/k/a THE ANTHEM COMPANIES INC., Defendant. DEFENDANT’S CONSENT MOTION FOR AN EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT Defendant Elevance Health, Inc. (“Elevance”), incorrectly identified as “Elevance Health Inc. f/k/a The Anthem Companies, Inc.,” by its attorneys and pursuant to Fla. R. Civ. P. 1.090(b), respectfully submits this Consent Motion for an Extension of Time to Answer or Otherwise Respond to Plaintiff’s Complaint. As grounds for this motion, Elevance states as follows: 1. Plaintiff filed her Complaint on April 23, 2024. 2. Elevance was served with the Summons and Complaint on June 18, 2024 making Elevance’s responsive pleading due on July 8, 2024. 3. Elevance and its counsel require additional time to fully investigate and respond to Plaintiff’s allegations and claims. 4. Accordingly, Elevance seeks an extension of 21 days, through and including July 29, 2024, to answer or otherwise respond to Plaintiff’s Complaint. 5. Elevance’s counsel conferred with Plaintiff’s counsel regarding this motion, and Plaintiff’s counsel consents to Elevance’s requested extension of time. 312213104v.1 7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 1 6. This request is made in good faith and will not affect any other deadlines or the just, speedy, and inexpensive determination of this action. This extension of time will allow Elevance sufficient time to fully investigate the allegations and claims raised by Plaintiff’s Complaint, confer with counsel, and prepare its response. This is Elevance’s first request for an extension of time. CERTIFICATE OF CONFERRAL On July 2, 2024, counsel for Elevance conferred with Plaintiff’s counsel via email regarding the requested enlargement of time. Plaintiff’s counsel confirmed that Plaintiff consents to the relief requested herein. WHEREFORE, Elevance respectfully requests that the Court grant this consent motion and extend Elevance’s deadline to answer or otherwise respond to Plaintiff’s Complaint through and including July 29, 2024. Dated: July 3, 2024 Respectfully submitted, SEYFARTH SHAW LLP By: /s/ Alex S. Drummond Alex S. Drummond Florida Bar No. 038307 adrummond@seyfarth.com SEYFARTH SHAW LLP 1075 Peachtree Street, N.E. Suite 2500 Atlanta, Georgia 30309-3958 Telephone: (404) 885-1500 Facsimile: (404) 892-7056 Counsel for Defendant Elevance Health, Inc. 2 312213104v.1 7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 2 IN THE CIRCUIT COURT OF THE 13TH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA TAMIKA FAULKNER, Plaintiff, vs. Case No. 24-CA-003323 ELEVANCE HEALTH INC f/k/a THE ANTHEM COMPANIES INC., Defendant. CERTIFICATE OF SERVICE I hereby certify that on July 3, 2024, I electronically filed this CONSENT MOTION FOR AN EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT with the Clerk of Court via the Florida e-Filing Portal, which will automatically send e-mail notification of such filing to all counsel of record, including: Anthony M. Georges-Pierre, Esq. agp@rgph.law REMER, GEORGES-PIERRE & HOOGERWOERD, PLLC 2745 Ponce De Leon Boulevard Coral Gables, Florida 33134 By: /s/ Alex S. Drummond________ Alex. S. Drummond Counsel For Defendant Elevance Health, Inc. 3 312213104v.1 7/3/2024 1:48 PM Electronically Filed: Hillsborough County/13th Judicial Circuit Page 3