EP - DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY - HICKS, CYNTHIA ANN vs. TOWER HILL SELECT INSURANCE COMPANY

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On August 28, 2019 a case was filed by Estate Of Angelina H Calvert, and Hicks, Cynthia Ann, represented by Smith, Kimesha S, against Tower Hill Select Insurance Company, represented by Fluet, Nicole M, in the jurisdiction of Bay County. Judge FISHEL, JOHN L II presiding.

                        
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                          Filing # 97254898 E-Filed 10/14/2019 05:43:54 PM.

IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA.

CYNTHIA ANN HICKS AS PERSONAL
REPRESENTATIVE OF THE ESTATE OF
ANGELINA H CALVERT, Case No.:
19003278CA
Plaintiff,
v.

TOWER HILL SELECT INSURANCE
COMPANY,

Defendant.
/

DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF’S DISCOVERY

Defendant, TOWER HILL SELECT INSURANCE COMPANY (“Tower Hill”), by and
through the undersigned counsel and pursuant to Rule 1.090(b), Florida Rules of Civil
Procedure, files this motion seeking an enlargement of time to respond to Plaintiff, CYNTHIA
ANN HICKS AS PERSONAL REPRESENTATIVE OF THE ESTATE OF ANGELINA H
CALVERT’s First Set of Interrogatories and First Request to Produce and states the following in
support:

1. Tower Hill was served with Plaintiff's Complaint on August 30, 2019. With the
Complaint, Plaintiff served her First Set of Interrogatories and First Request to Produce on
Tower Hill, mak…