On December 04, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Smith, James R,
Smith, Tessa,
and
Security First Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 108287563 E-Filed 06/02/2020 04:52:13 PM
IN THE CIRCUIT COURT OF THE 147
JUDICIAL CIRCUIT IN AND FOR BAY
COUNTY, FLORIDA
JAMES R. SMITH,
Plaintiff,
VS.
CASE NUMBER: 19004406CA.
SECURITY FIRST INSURANCE
COMPANY,
Defendant.
/
PLAINTIFF’S MOTION FOR PROTECTIVE ORDER
COMES NOW, Plaintiff, JAMES R. SMITH, by and through his undersigned counsel, and
pursuant to the applicable Florida Rules of Civil Procedure, hereby files this Motion for Protective
Order and states the following in support thereof:
1,
Plaintiff's lawsuit arises from a claim for homeowner insurance benefits under his
policy issued by Security First Insurance Company.
On or about May 15, 2020, Defendant requested to coordinate Plaintiff's deposition.
Plaintiffs counsel advised Defendant that the Plaintiff has suffered a second stroke and
is experiencing significant medical issues.
At present, the Plaintiff has limited mobility and is currently re-learning how to walk
again and is only able to do so with the assistance of a walker.
As such, Plaintiff’s counsel is requesting for Plaintiffs deposition to be postponed until
he has made a reasonable recovery such that he is physically able to sit for a deposition.
This motion is made in good faith and not for purpose of hindrance or delay.WHEREFORE, Plaintiffs, JAMES R. SMITH, request this Honorable Court grant
Plaintiffs’ Motion and enter an Order granting Plaintiffs motion, and for any other relief this Court
deems just and proper.
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail
via the Florida courts E-filing Portal on this day 2"! day of June 2020.
KANDELL, KANDELL, & PETRIE.
Attorneys for Plaintiffs
Document Filed Date
June 02, 2020
Case Filing Date
December 04, 2019
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Filing # 108287563 E-Filed 06/02/2020 04:52:13 PM IN THE CIRCUIT COURT OF THE 147 JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA JAMES R. SMITH, Plaintiff, VS. CASE NUMBER: 19004406CA. SECURITY FIRST INSURANCE COMPANY, Defendant. / PLAINTIFF’S MOTION FOR PROTECTIVE ORDER COMES NOW, Plaintiff, JAMES R. SMITH, by and through his undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure, hereby files this Motion for Protective Order and states the following in support thereof: 1, Plaintiff's lawsuit arises from a claim for homeowner insurance benefits under his policy issued by Security First Insurance Company. On or about May 15, 2020, Defendant requested to coordinate Plaintiff's deposition. Plaintiffs counsel advised Defendant that the Plaintiff has suffered a second stroke and is experiencing significant medical issues. At present, the Plaintiff has limited mobility and is currently re-learning how to walk again and is only able to do so with the assistance of a walker. As such, Plaintiff’s counsel is requesting for Plaintiffs deposition to be postponed until he has made a reasonable recovery such that he is physically able to sit for a deposition. This motion is made in good faith and not for purpose of hindrance or delay.WHEREFORE, Plaintiffs, JAMES R. SMITH, request this Honorable Court grant Plaintiffs’ Motion and enter an Order granting Plaintiffs motion, and for any other relief this Court deems just and proper. CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail via the Florida courts E-filing Portal on this day 2"! day of June 2020. KANDELL, KANDELL, & PETRIE. Attorneys for Plaintiffs