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.
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Filing # 101211226 E-Filed 01/07/2020 08:40:14 AM
IN THE CIRCUIT COURT OF THE 14TH
JUDICIAL CIRCUIT IN AND FOR BAY
COUNTY, FLORIDA
CASE NO.: 19004406CA
JAMES R. SMITH,
Plaintiff,
v.
SECURITY FIRST INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW Defendant, SECURITY FIRST INSURANCE COMPANY, by and
through its undersigned counsel, and pursuant to the Florida Rule of Civil Procedure
1.090(b) and hereby moves for an extension of time to respond to the Plaintiff's Complaint
and as grounds therefore states as follows:
1. Plaintiff has sued the Defendant for damages in the above-styled action.
2. Plaintiffs Complaint was filed on December 4,2019 and served on
December 17,2019.
3. The undersigned was only recently retained in this matter and requires
additional time to confer with Defendant in order to respond to the lawsuit.
4. The Plaintiff will not be prejudiced by the granting of this Motion.
COLE, SCOTT & KISSANE, P.A.
4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2900 FAXCASE NO.: 19004406CA
5. There is no trial pending in this matter at this time, and this Motion is not
intended for the purposes of delay. The granting of this motion will not prejudice either
party.
6. Defendant respectfully requests this Court to enter an Order granting an
extension within which to respond to Plaintiff's Complaint.
WHEREFORE, Defendant, SECURITY FIRST INSURANCE COMPANY,
respectfully requests this Honorable Court enter an Order granting its Motion for
Extension of Time to Respond to Plaintiff's Complaint.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 7th day of January, 2020, a true and correct copy
of the foregoing was filed with the Clerk of BAY County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties
registered with the e-Filing Portal system: Justin Petrie, Esq., Kandell, Kandell & Petrie,
justin@kandelllaw.com;justin@kkpfirm.com;jenni@kkpfirm.com, 2665 S. Bayshore
Drive, Suite 601, Coconut Grove, FL 33133, (305) 858-2220/(305) 858-2722 (F), Attorney
for Plaintiff, James R. Smith.
2
COLE, SCOTT & KISSANE, P.A.
4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2000 FAX0504.3686-00/ 16868777
By:
CASE NO.: 19004406CA
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant SECURITY FIRST
INSURANCE COMPANY
4301 West Boy Scout Boulevard
Suite 400
Tampa, Florida 33607
Telephone (813) 864-9330
Facsimile (813) 286-2900
Primary e-mail: paydon.broeder@csklegal.com
Secondary e-mail:
katherine. moran@csklegal.com
Alternate e-mail: tiffany.coleman@csklegal.com
s/ Katherine Moran
PAYDON R. BROEDER
Florida Bar No.: 106881
KATHERINE MORAN
Florida Bar No.: 1018653
3
COLE, SCOTT & KISSANE, P.A.
4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2000 FAX
Document Filed Date
January 07, 2020
Case Filing Date
December 04, 2019
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Filing # 101211226 E-Filed 01/07/2020 08:40:14 AM IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004406CA JAMES R. SMITH, Plaintiff, v. SECURITY FIRST INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW Defendant, SECURITY FIRST INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to the Florida Rule of Civil Procedure 1.090(b) and hereby moves for an extension of time to respond to the Plaintiff's Complaint and as grounds therefore states as follows: 1. Plaintiff has sued the Defendant for damages in the above-styled action. 2. Plaintiffs Complaint was filed on December 4,2019 and served on December 17,2019. 3. The undersigned was only recently retained in this matter and requires additional time to confer with Defendant in order to respond to the lawsuit. 4. The Plaintiff will not be prejudiced by the granting of this Motion. COLE, SCOTT & KISSANE, P.A. 4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2900 FAXCASE NO.: 19004406CA 5. There is no trial pending in this matter at this time, and this Motion is not intended for the purposes of delay. The granting of this motion will not prejudice either party. 6. Defendant respectfully requests this Court to enter an Order granting an extension within which to respond to Plaintiff's Complaint. WHEREFORE, Defendant, SECURITY FIRST INSURANCE COMPANY, respectfully requests this Honorable Court enter an Order granting its Motion for Extension of Time to Respond to Plaintiff's Complaint. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 7th day of January, 2020, a true and correct copy of the foregoing was filed with the Clerk of BAY County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Justin Petrie, Esq., Kandell, Kandell & Petrie, justin@kandelllaw.com;justin@kkpfirm.com;jenni@kkpfirm.com, 2665 S. Bayshore Drive, Suite 601, Coconut Grove, FL 33133, (305) 858-2220/(305) 858-2722 (F), Attorney for Plaintiff, James R. Smith. 2 COLE, SCOTT & KISSANE, P.A. 4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2000 FAX0504.3686-00/ 16868777 By: CASE NO.: 19004406CA COLE, SCOTT & KISSANE, P.A. Counsel for Defendant SECURITY FIRST INSURANCE COMPANY 4301 West Boy Scout Boulevard Suite 400 Tampa, Florida 33607 Telephone (813) 864-9330 Facsimile (813) 286-2900 Primary e-mail: paydon.broeder@csklegal.com Secondary e-mail: katherine. moran@csklegal.com Alternate e-mail: tiffany.coleman@csklegal.com s/ Katherine Moran PAYDON R. BROEDER Florida Bar No.: 106881 KATHERINE MORAN Florida Bar No.: 1018653 3 COLE, SCOTT & KISSANE, P.A. 4301 WEST BOY SCOUT BOULEVARD - SUITE 400 - TAMPA, FLORIDA 33607 - (813) 289-9300 - (813) 286-2000 FAX