Party Notice: ADVANCED CHIROPRACTIC AND REHABILITATION CENTER INC , AS ASSIGNEE OF- FOR BERNADETTE DONATO Vs. 21ST CENTURY CENTENNIAL INSURANCE COMPANY

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                                Filing # 63245261 E-Filed 10/24/2017 01:37:20 PM


                            IN THE COUNTY COURT OF THE SIXTH JUDICIAL CIRCUIT
                                   IN AND FOR PINELLAS COUNTY, FLORIDA
                                               CIVIL DIVISION
                                             Case No.: 16-012134-SC

          ADVANCED          CHIROPRACTIC AND REHABILITATION, INC.,
          As assignee of Bernadette Donato,

                            Plaintiff(s),

          VS.



          218' CENTURY CENTENNIAL INSURNACE COMPANY,

                            Defendant.
                                                          /

                                       PLAINTIFF’S STATEMENT OF GOOD            CAUSE

                    The   Plaintiff,   ADVANCED     CHIROPRACTIC        AND    REHABILITATION,        INC,   as
          assignee

          of Bernadette Donato, by and through the undersigned attorney, hereby responds to the Clerk of
          the

          Circuit Court’s Notice of Lack of Prosecution dated October 20, 2017, and attached hereto as
          Exhibit

          “A” as follows:

                     1      Plaintiff originally filed the above-styled cause of action based on Defendant’s

          breach of contract for failing to pay Personal Injury Protection (PIP) benefits.

                     2.     The parties have also entered into preliminary settlement discussions, which still

          remain a possibility at this time.

                     3      Plaintiff served discovery with the Complaint. As of the date of this Statement of

          Good Cause, Defendant has failed to serve complete responses to Plaintiff’s discovery requests.

          Plaintiff is in need of these discovery responses in order to properly prepare its case for trial.

          Plaintiff is currently attempting to resolve this matter with Defendant without the need for court




***ELECTRONICALLY FILED 10/24/2017 01:37:20 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
intervention.

        4.      Plaintiff intends to notice this case for trial at the appropriate time in the event a

settlement is not reached.

        5       Based on the reasoning set forth above, the Plaintiff believes good cause exists as

to why this case should remain pending.

      WHEREFORE,              the     Plaintiff,        ADVANCED           CHIROPRACTIC         AND
REHABILITATION,

INC, as assignee of Bernadette Donato, respectfully requests this Court to find good cause exists
to

allow this case to remain pending in order to avoid dismissal of this case for lack of prosecution.

                                    CERTIFICATE OF SERVICE

        I HEREBY      CERTIFY       that a true and correct copy of the foregoing was served by

electronic mail on the 24" day of October, 2017, to:



Primary:        tampapip@farmersinsurance.com




                                                   Reeder & Nussbaum, P.A.


                                                   /s Andrew D Reeder
                                                   Andrew D. Reeder, Esquire
                                                   2201 4th Street North, Suite G
                                                   St. Petersburg, FL 33704
                                                   727521-2889
                                                   FBN 0388424
                                                   Attomey for Plaintiff
                                                   attorney@counselorsoflaw.com
“EXHIBIT A”