On December 04, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Carr, Jamie,
Carr, Jennifer,
and
Gulfstream Property & Casualty Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 103072551 E-Filed 02/10/2020 05:07:02 PM
IN THE CIRCUIT COURT OF THE
14™ JUDICIAL CIRCUIT IN AND
FOR BAY COUNTY, FLORIDA
CASE NO.: 19004412CA
JAMIE AND JENNIFER CARR,
Plaintiffs,
v.
GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFFS’ DISCOVERY REQUESTS
COMES NOW, the Defendant, GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to Fla.
R. Civ. P. 1.090(b) and hereby files this Motion for Extension of Time to Respond to
Plaintiffs’ Discovery Requests and in support thereof states the following:
1. Defendant's responses to Plaintiffs’ discovery requests are due on
February 10, 2020.
2. The undersigned counsel requires additional time to respond to Plaintiffs’
Request for Production, Initial Interrogatories and Request for Admissions.
3. Accordingly, Defendant respectfully requests that this Court grant
Defendant an extension to respond to Plaintiffs’ discovery requests.
4. This matter is not scheduled for trial or pretrial conference.
5. No party will be prejudiced as a result of the requested extension of time.WHEREFORE, Defendant, GULFSTREAM PROPERTY & CASUALTY
INSURANCE COMPANY, respectfully requests this Honorable Court grant an extension
of time within which to respond to Plaintiffs’ Request for Production, Request for
Admissions and Initial Interrogatories.
BUTLER WEIHMULLER KATZ CRAIG LLP
KATHY J. MAUS, ESQ.
Florida Bar No.: 0896330
kmaus@butler.legal
JULIUS F. PARKER, Ill, ESQ.
Florida Bar No.: 0160857
jparker@butler.legal
Secondary: apinnock@butler.legal
Mail Center: 400 North Ashley Drive, Suite 2300
Tampa, FL 33602
Telephone: (850) 894-4111
Facsimile: (850) 894-4999
Attorneys for Defendant
CERTIFICATE OF SERVICE
| certify that a copy hereof has been furnished to:
Scott M. Rosso, Esq.
David R. Shaheen, Esq.
GED Lawyers, LLP
7171 North Federal Highway
Boca Raton, FL 33487
pdlitlaw@gedlawyers.com
Secondary: bluque@gedlawyers.com
Attorneys For: Plaintiffs
by e-Portal and e-Service on February 10, 2020.
JULIUS F. PARKER, III, ESQ.
Document Filed Date
February 10, 2020
Case Filing Date
December 04, 2019
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Filing # 103072551 E-Filed 02/10/2020 05:07:02 PM IN THE CIRCUIT COURT OF THE 14™ JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 19004412CA JAMIE AND JENNIFER CARR, Plaintiffs, v. GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ DISCOVERY REQUESTS COMES NOW, the Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to Fla. R. Civ. P. 1.090(b) and hereby files this Motion for Extension of Time to Respond to Plaintiffs’ Discovery Requests and in support thereof states the following: 1. Defendant's responses to Plaintiffs’ discovery requests are due on February 10, 2020. 2. The undersigned counsel requires additional time to respond to Plaintiffs’ Request for Production, Initial Interrogatories and Request for Admissions. 3. Accordingly, Defendant respectfully requests that this Court grant Defendant an extension to respond to Plaintiffs’ discovery requests. 4. This matter is not scheduled for trial or pretrial conference. 5. No party will be prejudiced as a result of the requested extension of time.WHEREFORE, Defendant, GULFSTREAM PROPERTY & CASUALTY INSURANCE COMPANY, respectfully requests this Honorable Court grant an extension of time within which to respond to Plaintiffs’ Request for Production, Request for Admissions and Initial Interrogatories. BUTLER WEIHMULLER KATZ CRAIG LLP KATHY J. MAUS, ESQ. Florida Bar No.: 0896330 kmaus@butler.legal JULIUS F. PARKER, Ill, ESQ. Florida Bar No.: 0160857 jparker@butler.legal Secondary: apinnock@butler.legal Mail Center: 400 North Ashley Drive, Suite 2300 Tampa, FL 33602 Telephone: (850) 894-4111 Facsimile: (850) 894-4999 Attorneys for Defendant CERTIFICATE OF SERVICE | certify that a copy hereof has been furnished to: Scott M. Rosso, Esq. David R. Shaheen, Esq. GED Lawyers, LLP 7171 North Federal Highway Boca Raton, FL 33487 pdlitlaw@gedlawyers.com Secondary: bluque@gedlawyers.com Attorneys For: Plaintiffs by e-Portal and e-Service on February 10, 2020. JULIUS F. PARKER, III, ESQ.