On December 04, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Odom, Patsy J,
and
Tower Hilll Signature Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 102142089 E-Filed 01/23/2020 04:48:17 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
PATSY J. ODOM,
Plaintiff,
v. Case No.: 19-004405 CA
TOWER HILL SIGNATURE INSURANCE
COMPANY, a Florida insurance corporation,
Defendant.
/
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF’S DISCOVERY
Defendant, TOWER HILL SIGNATURE 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, PATSY J. ODOM’s, First Set
of Interrogatories and First Request for Production of Documents and states the following in
support:
1. Tower Hill was served with Plaintiff's Complaint on December 9, 2019. With the
Complaint, Plaintiff served their First Set of Interrogatories and First Request for Production of
Documents on Tower Hill, making the responses due on or before January 23, 2020.
2. Tower Hill respectfully requests that this Court enlarge the time in which to
respond to Plaintiff’s First Set of Interrogatories and First Request for Production of Documents.
3. Tower Hill does not request this enlargement of time for purposes of vexation or
delay, and no party will be prejudiced by the enlargement of time.
WHEREFORE, Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY,
respectfully requests that this Court enlarge the time in which to respond to the First Set of
Page 1 of 2Interrogatories and First Request for Production of Documents filed by Plaintiff, PATSY J.
ODOM, and for any and all other relief this Court deems equitable and just.
/s/ Nicole M. Fluet
NICOLE M. FLUET, Fla. Bar No. 91077
nfluet@gallowaylawfirm.com
SARAH K. CULLETON, Fla. Bar No. 1015231
sculleton@gallowaylawfirm.com
Galloway, Johnson, Tompkins, Burr & Smith, PLC
400 N. Ashley Drive, Suite 1000
Tampa, Florida 33602
(813) 977-1200
(813) 977-1288 (facsimile)
tampaservice@gallowaylawfirm.com
Counsel for Defendant, Tower Hill Signature
Insurance Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to
the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 23rd day
of January 2020:
Clark Hamilton, Jr., Esq.
Tyler & Hamilton, P.A.
Midtown Centre, Building 4000
4811 Beach Boulevard, Suite 200
Jacksonville, Florida 32207
Phone: 904-398-9999
Fax: 904-398-0806
courtdocs@floridainsurancelawyers.com
tandhpa@bellsouth.net
Counsel for Plaintiff
Jay Manuel, Esq.
Manuel & Thompson, P.A.
120 Richard Jackson Boulevard, Suite 200
Panama City, Florida 325407
Phone: 850-785-5555
Fax: 850-785-0133
jay@manuelthompson.com
velinda@manuelthompson.com
tim@manuelthompson.com
Counsel for Plaintiff
[>| Nicale M. Fluct
NICOLE M. FLUET
SARAH K. CULLETON
Page 2 of 2
Document Filed Date
January 23, 2020
Case Filing Date
December 04, 2019
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Filing # 102142089 E-Filed 01/23/2020 04:48:17 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA PATSY J. ODOM, Plaintiff, v. Case No.: 19-004405 CA TOWER HILL SIGNATURE INSURANCE COMPANY, a Florida insurance corporation, Defendant. / DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S DISCOVERY Defendant, TOWER HILL SIGNATURE 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, PATSY J. ODOM’s, First Set of Interrogatories and First Request for Production of Documents and states the following in support: 1. Tower Hill was served with Plaintiff's Complaint on December 9, 2019. With the Complaint, Plaintiff served their First Set of Interrogatories and First Request for Production of Documents on Tower Hill, making the responses due on or before January 23, 2020. 2. Tower Hill respectfully requests that this Court enlarge the time in which to respond to Plaintiff’s First Set of Interrogatories and First Request for Production of Documents. 3. Tower Hill does not request this enlargement of time for purposes of vexation or delay, and no party will be prejudiced by the enlargement of time. WHEREFORE, Defendant, TOWER HILL SIGNATURE INSURANCE COMPANY, respectfully requests that this Court enlarge the time in which to respond to the First Set of Page 1 of 2Interrogatories and First Request for Production of Documents filed by Plaintiff, PATSY J. ODOM, and for any and all other relief this Court deems equitable and just. /s/ Nicole M. Fluet NICOLE M. FLUET, Fla. Bar No. 91077 nfluet@gallowaylawfirm.com SARAH K. CULLETON, Fla. Bar No. 1015231 sculleton@gallowaylawfirm.com Galloway, Johnson, Tompkins, Burr & Smith, PLC 400 N. Ashley Drive, Suite 1000 Tampa, Florida 33602 (813) 977-1200 (813) 977-1288 (facsimile) tampaservice@gallowaylawfirm.com Counsel for Defendant, Tower Hill Signature Insurance Company CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished to the following via the Florida Courts E-Filing Portal and/or electronic mail delivery this 23rd day of January 2020: Clark Hamilton, Jr., Esq. Tyler & Hamilton, P.A. Midtown Centre, Building 4000 4811 Beach Boulevard, Suite 200 Jacksonville, Florida 32207 Phone: 904-398-9999 Fax: 904-398-0806 courtdocs@floridainsurancelawyers.com tandhpa@bellsouth.net Counsel for Plaintiff Jay Manuel, Esq. Manuel & Thompson, P.A. 120 Richard Jackson Boulevard, Suite 200 Panama City, Florida 325407 Phone: 850-785-5555 Fax: 850-785-0133 jay@manuelthompson.com velinda@manuelthompson.com tim@manuelthompson.com Counsel for Plaintiff [>| Nicale M. Fluct NICOLE M. FLUET SARAH K. CULLETON Page 2 of 2