Preview
Filing # 133417078 E-Filed 08/25/2021 04:14:55 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASENO.: —50-2020-CA-007463-XXXX-MB
ROODY ST. GERMAIN,
Plaintiff,
v.
ROADRUNNER SERVICES, LLC., and
MANHEIM REMARKETING, INC.,
Defendants.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANT, ROADRUNNE! IRVICES, LLC’S DISCOVERY REQUEST
COMES NOW, the Plaintiff, ROODY ST. GERMAIN, by and through the undersigned
counsel and hereby moves this Honorable Court, pursuant to Fla. R. Civ. P. 1.090(b), for an extension
of time to respond to Defendant, ROADRUNNER SERVICES, LLC’s discovery request and hereby
states as follows:
1. On June 24, 2021, Plaintiff, ROODY ST. GERMAIN, filed his Complaint on the above-
referenced matter.
2. On July 26, 2021, Defendant, ROADRUNNER SERVICES, LLC., served Plaintiff with its
First Request to Produce, and Initial Interrogatories.
3. Per the requirements of this Court, responses to discovery are due on August 25, 2021.
4. Plaintiff's counsel is hereby requesting an extension of time to respond to Defendant,
ROADRUNNER SERVICES, LLC’s discovery request.
5. The Plaintiff would further state that the Defendant, ROADRUNNER SERVICES, LLC’s
would not be prejudiced by this extension of time.
WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter an Order
allowing Fiamiiil additional time witnin io file responsive pleadings to Defendant, ROADRUNNER
SERVICES, LLC’s discovery request.
Page 1 of 2
CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED N@INEINNA, NAA AEE DN
PILL. PAL DLA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, Yureuieue to Ut. ite citCERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the was filed electronically and was
sent by E-Mail from the Florida’s Court’s E-Filing Portal system, unless other noted below, on all
counsel or parties of record listed below, this 25" day of August, 2021. The foregoing document has
also been sent from the undersigned counsel by E-Mail to all counsel or parties of record listed
below.
Steven R. Main, Esq.
Hill Rugh Keller & Main, P.L.
Attorneys for Defendant, Manheim Remarketing, Inc.
390 N. Orange Ave., Suite 1610
Orlando, FL 32801
smain@hrkmlaw.com; filings@hrkmlaw.com
Jessica R. King, Esq.
Law Office of Ignacio M. Sarmiento
Attorneys for Defendant, Roadrunner Services, LLC
P.O. Box 7217
London, KY 40742
bocalegalmail@libertymutual.com;
Jessica.king@libertymutual.com
SCHULER, HALVORSON, WEISSER,
ZOELLER, OVERBECK & BAXTER, P.A.
Attorneys for Plaintiff
Barristers Building
1615 Forum Place, Suite 4D
West Palm Beach, FL 33401
(561) 689-8180
By: /s/ Gregory M. Cummings, Esq.
WILLIAM D. ZOELLER
Fla. Bar No.: 155233
wzoeller@shw-law.com
tcoffey@shw-law.com
GREGORY M. CUMMINGS
Fla. Bar No.: 126074
geummings@shw-law.com
jdaza@shw-law.com
Page 2 of 2
Preview
Filing # 133417078 E-Filed 08/25/2021 04:14:55 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASENO.: —50-2020-CA-007463-XXXX-MB ROODY ST. GERMAIN, Plaintiff, v. ROADRUNNER SERVICES, LLC., and MANHEIM REMARKETING, INC., Defendants. / PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT, ROADRUNNE! IRVICES, LLC’S DISCOVERY REQUEST COMES NOW, the Plaintiff, ROODY ST. GERMAIN, by and through the undersigned counsel and hereby moves this Honorable Court, pursuant to Fla. R. Civ. P. 1.090(b), for an extension of time to respond to Defendant, ROADRUNNER SERVICES, LLC’s discovery request and hereby states as follows: 1. On June 24, 2021, Plaintiff, ROODY ST. GERMAIN, filed his Complaint on the above- referenced matter. 2. On July 26, 2021, Defendant, ROADRUNNER SERVICES, LLC., served Plaintiff with its First Request to Produce, and Initial Interrogatories. 3. Per the requirements of this Court, responses to discovery are due on August 25, 2021. 4. Plaintiff's counsel is hereby requesting an extension of time to respond to Defendant, ROADRUNNER SERVICES, LLC’s discovery request. 5. The Plaintiff would further state that the Defendant, ROADRUNNER SERVICES, LLC’s would not be prejudiced by this extension of time. WHEREFORE, the Plaintiff respectfully requests this Honorable Court enter an Order allowing Fiamiiil additional time witnin io file responsive pleadings to Defendant, ROADRUNNER SERVICES, LLC’s discovery request. Page 1 of 2 CHEN. DAIAARCACUAAIINTY Cl INCEDU ARDIIV7ZN FLED N@INEINNA, NAA AEE DN PILL. PAL DLA VUUINE TT, FL, JUOL IE mDNUeeY, ULLIAN, Yureuieue to Ut. ite citCERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the was filed electronically and was sent by E-Mail from the Florida’s Court’s E-Filing Portal system, unless other noted below, on all counsel or parties of record listed below, this 25" day of August, 2021. The foregoing document has also been sent from the undersigned counsel by E-Mail to all counsel or parties of record listed below. Steven R. Main, Esq. Hill Rugh Keller & Main, P.L. Attorneys for Defendant, Manheim Remarketing, Inc. 390 N. Orange Ave., Suite 1610 Orlando, FL 32801 smain@hrkmlaw.com; filings@hrkmlaw.com Jessica R. King, Esq. Law Office of Ignacio M. Sarmiento Attorneys for Defendant, Roadrunner Services, LLC P.O. Box 7217 London, KY 40742 bocalegalmail@libertymutual.com; Jessica.king@libertymutual.com SCHULER, HALVORSON, WEISSER, ZOELLER, OVERBECK & BAXTER, P.A. Attorneys for Plaintiff Barristers Building 1615 Forum Place, Suite 4D West Palm Beach, FL 33401 (561) 689-8180 By: /s/ Gregory M. Cummings, Esq. WILLIAM D. ZOELLER Fla. Bar No.: 155233 wzoeller@shw-law.com tcoffey@shw-law.com GREGORY M. CUMMINGS Fla. Bar No.: 126074 geummings@shw-law.com jdaza@shw-law.com Page 2 of 2