On March 23, 2016 a
Motion,Ex Parte
was filed
involving a dispute between
and
for County and Admin Appeals (AP)
in the District Court of Miami-Dade County.
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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI DADE COUNTY, FLORIDA
STATE FARM MUTUAL
AUTOMOBILE INSURANCE
COMPANY, Appeal No: 16-000121-AP-01
Appellant, L.T. Case No: 14-3283-SP 23 (3)
v. ~
PAN AM DIAGNOSTIC SERVICES INC. S s Q
d/b/a Wide Open MRI 5 a.
(a/a/o Maxime Jean Louis), ~~ Ss
oe
Appellee. Ss.
! 3
UNOPPOSED MOTION FOR EXTENSION OF TIME
Appellant STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY pursuant to Florida Rule of Appellate Procedure 9.300(a) requests that
the Court extend the time for service of its initial brief for 15 days to November 15,
2016, and states:
The initial brief is currently due on October 31, 2016. The brief is
1.
substantially complete; however, undersigned counsel needs approval from the
client for filing.
A 15-day extension should provide adequate time for client approval.
2.
This is Appellant’s third request for a briefing extension, and this request is not
being made for purposes of delay or any other improper purpose.4, Undersigned counsel has contacted counsel for the Appellee, Robert J.
Hauser, Esq., and is authorized to represent that he has no objection to this request.
WHEREFORE, Appellant STATE FARM MUTUAL AUTOMOBILE
INSURANCE COMPANY respectfully requests that the Court extend the time for
service of its initial brief for 15 days to November 15, 2016.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing has been filed with the court via
USS. Mail and that a copy of the foregoing has been furnished by e-mail to: Omar
A. Giraldo, Esquire, Counsel for Defendant/Appellant, 600 North Pine Island Rd.,
Plantation, Florida 33324 at omar.giraldo@csklegal.com; Yigal D. Kahana,
Esquire, Counsel for Plaintiff/Appellee, 12000 Biscayne Blvd., Suite 403, North
Miami, Florida 33181 at yigal@kahanalegal.com; and Robert J. Hauser, Esquire,
Counsel for Plaintiff/Appellee, Pankauski Law Firm, PLLC, 120 — South Olive
Avenue, Suite 701, West Palm Beach, FL 33401 atcourtfilings@pankauskilawfirm.com and hauser@pankauskilawfirm.com; this
October 26, 2016.
BANKER LOPEZ GASSLER P.A.
360 Central Avenue
Suite 700
St. Petersburg, FL 33701
Phone: (727) 825-3600
Fax: (727) 821-1968
e-mail: dmclemore@bankerlopez.com
service e-mail:
service-dmclemore@bankerlopez.com
service-mtinker@bankerlopez.com
Attorneys for State Farm
By:_/s/ DeeAnn J. McLemore, Esq.
DeeAnn J. McLemore, Esq.
Florida Bar No: 0113065
Mark D. Tinker, Esq., B.C.S.
Florida Bar No: 0585165
Document Filed Date
October 31, 2016
Case Filing Date
March 23, 2016
Category
County and Admin Appeals (AP)
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IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Appeal No: 16-000121-AP-01 Appellant, L.T. Case No: 14-3283-SP 23 (3) v. ~ PAN AM DIAGNOSTIC SERVICES INC. S s Q d/b/a Wide Open MRI 5 a. (a/a/o Maxime Jean Louis), ~~ Ss oe Appellee. Ss. ! 3 UNOPPOSED MOTION FOR EXTENSION OF TIME Appellant STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY pursuant to Florida Rule of Appellate Procedure 9.300(a) requests that the Court extend the time for service of its initial brief for 15 days to November 15, 2016, and states: The initial brief is currently due on October 31, 2016. The brief is 1. substantially complete; however, undersigned counsel needs approval from the client for filing. A 15-day extension should provide adequate time for client approval. 2. This is Appellant’s third request for a briefing extension, and this request is not being made for purposes of delay or any other improper purpose.4, Undersigned counsel has contacted counsel for the Appellee, Robert J. Hauser, Esq., and is authorized to represent that he has no objection to this request. WHEREFORE, Appellant STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY respectfully requests that the Court extend the time for service of its initial brief for 15 days to November 15, 2016. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing has been filed with the court via USS. Mail and that a copy of the foregoing has been furnished by e-mail to: Omar A. Giraldo, Esquire, Counsel for Defendant/Appellant, 600 North Pine Island Rd., Plantation, Florida 33324 at omar.giraldo@csklegal.com; Yigal D. Kahana, Esquire, Counsel for Plaintiff/Appellee, 12000 Biscayne Blvd., Suite 403, North Miami, Florida 33181 at yigal@kahanalegal.com; and Robert J. Hauser, Esquire, Counsel for Plaintiff/Appellee, Pankauski Law Firm, PLLC, 120 — South Olive Avenue, Suite 701, West Palm Beach, FL 33401 atcourtfilings@pankauskilawfirm.com and hauser@pankauskilawfirm.com; this October 26, 2016. BANKER LOPEZ GASSLER P.A. 360 Central Avenue Suite 700 St. Petersburg, FL 33701 Phone: (727) 825-3600 Fax: (727) 821-1968 e-mail: dmclemore@bankerlopez.com service e-mail: service-dmclemore@bankerlopez.com service-mtinker@bankerlopez.com Attorneys for State Farm By:_/s/ DeeAnn J. McLemore, Esq. DeeAnn J. McLemore, Esq. Florida Bar No: 0113065 Mark D. Tinker, Esq., B.C.S. Florida Bar No: 0585165