On December 10, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Bodner, Donna,
and
Tower Hill Select Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 104864738 E-Filed 03/13/2020 03:00:10 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CIVIL DIVISION
DONNA BODNER,
Plaintiff, Case No. 19-004473-CA
vs.
TOWER HILL SELECT
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT’S FIRST DISCOVERY REQUESTS
COMES NOW the Plaintiff, DONNA BODNER (“MS. BODNER’), by and through
her undersigned attorney, hereby files her Motion for Extension of Time to Respond to
Defendant's, TOWER HILL SELECT INSURANCE COMPANY (“TOWER HILL’), First
Set of Interrogatories and First Request for Production, and states as follows:
1. On or about February 13, 2020, TOWER HILL served its First Set of
Interrogatories and First Request for Production upon MS. BODNER.
2. MS. BODNER is in the process of responding to the discovery requests
but requires additional time in order to fully and properly respond.
3. This Motion is being made in good faith and not for the purposes of delay
or prejudice, but solely for the purpose of having adequate time to prepare complete
and proper responses. An extension of time will not prejudice any party.
4. MS. BODNER does not waive any of her objections she may assert in
response to TOWER HILL’S first discovery requests by the filing of this Motion for
Extension of Time.WHEREFORE the Plaintiff, DONNA BODNER, respectfully requests that this
Honorable Court grant an extension of time to respond to Defendant's First Set of
Interrogatories and First Request for Production, and for any other and further relief this
Court deems proper.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on March 13, 2020, the foregoing has been
electronically filed with the Clerk of Court by using the Florida Courts eFiling Portal system
which will send a Notice of Electronic Filing to all counsel of record as follows:
Gregory M. Shoemaker, Esquire
Wade, Palmer & Shoemaker
14 North Palafox Street
Pensacola, Florida 32502
ishoemaker@wpslawyers.com
ssmith@wpslawyers.com
cschreiner@wpslawyers.com
li David J. Pettinato-
DAVID J. PETTINATO, ESQUIRE
Florida Bar Number: 062324
MERLIN LAW GROUP, P.A.
777 S. Harbour Island Blvd., Suite 950
Tampa, Florida 33602
Tel.: (813) 229-1000
Fax: (813) 229-3692
Attorney for Plaintiff
dpettinato@merlinilawgroup.com
smerriett@merliniawgroup.com
trodriguez@merlinlawgroup.com
Document Filed Date
March 13, 2020
Case Filing Date
December 10, 2019
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Filing # 104864738 E-Filed 03/13/2020 03:00:10 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CIVIL DIVISION DONNA BODNER, Plaintiff, Case No. 19-004473-CA vs. TOWER HILL SELECT INSURANCE COMPANY, Defendant. / PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S FIRST DISCOVERY REQUESTS COMES NOW the Plaintiff, DONNA BODNER (“MS. BODNER’), by and through her undersigned attorney, hereby files her Motion for Extension of Time to Respond to Defendant's, TOWER HILL SELECT INSURANCE COMPANY (“TOWER HILL’), First Set of Interrogatories and First Request for Production, and states as follows: 1. On or about February 13, 2020, TOWER HILL served its First Set of Interrogatories and First Request for Production upon MS. BODNER. 2. MS. BODNER is in the process of responding to the discovery requests but requires additional time in order to fully and properly respond. 3. This Motion is being made in good faith and not for the purposes of delay or prejudice, but solely for the purpose of having adequate time to prepare complete and proper responses. An extension of time will not prejudice any party. 4. MS. BODNER does not waive any of her objections she may assert in response to TOWER HILL’S first discovery requests by the filing of this Motion for Extension of Time.WHEREFORE the Plaintiff, DONNA BODNER, respectfully requests that this Honorable Court grant an extension of time to respond to Defendant's First Set of Interrogatories and First Request for Production, and for any other and further relief this Court deems proper. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on March 13, 2020, the foregoing has been electronically filed with the Clerk of Court by using the Florida Courts eFiling Portal system which will send a Notice of Electronic Filing to all counsel of record as follows: Gregory M. Shoemaker, Esquire Wade, Palmer & Shoemaker 14 North Palafox Street Pensacola, Florida 32502 ishoemaker@wpslawyers.com ssmith@wpslawyers.com cschreiner@wpslawyers.com li David J. Pettinato- DAVID J. PETTINATO, ESQUIRE Florida Bar Number: 062324 MERLIN LAW GROUP, P.A. 777 S. Harbour Island Blvd., Suite 950 Tampa, Florida 33602 Tel.: (813) 229-1000 Fax: (813) 229-3692 Attorney for Plaintiff dpettinato@merlinilawgroup.com smerriett@merliniawgroup.com trodriguez@merlinlawgroup.com