On December 16, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Union Restoration Inc,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
Preview
Filing # 102716179 E-Filed 02/04/2020 01:01:51 PM
1938103
IN THE CIRCUIT COURT OF THE 14TH JUDICIAL
CIRCUIT IN AND FOR BAY COUNTY, FLORIDA
CASE NO. 19004524CA
UNION RESTORATION, INC., a/a/o RAQUEL
ESTRADA,
Plaintiff,
v.
EDISON INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFFS' DISCOVERY REQUESTS
Defendant, Edison Insurance Company, by and through its undersigned counsel,
moves this Honorable Court for the entry of an Order extending Defendant's time to
respond to Plaintiffs’; UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Initial
Interrogatories and Request to Produce served with the Complaint, and as grounds
therefore, would state as follows:
1. Counsel for Defendant has been unable to fully review Plaintiffs’ Initial
Interrogatories and Request to Produce, and respond to same.
2. The Defendant needs additional time in order to fully and properly respond
to Plaintiffs' discovery.
3. This motion is not meant to harass or prejudice the Plaintiff(s) or cause any
hindrance or delay.
4. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the
time within which to respond to Plaintiffs' outstanding discovery.CASE NO. 19004524CA
5. The Defendant reserves its right to object to any of Plaintiffs’ discovery
requests based on work-product and/or attorney-client privilege or other applicable
privilege, protection or immunity from discovery and specifically reserves its right to
subsequently raise same.
6. No prejudice will occur to the Plaintiff(s) if an extension of time is granted.
WHEREFORE, the Defendant, Edison Insurance Company respectfully requests
this Honorable Court grant the Defendant a thirty (30) day extension in which to respond
to Plaintiffs’, UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Initial
Interrogatories and Request to Produce, and/or grant any other relief deemed just and
proper.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy hereof has been furnished by service through the
eportal to Larry Moskowitz, Esq., Larry Moskowitz, P.A., 400 Southeast 9th Street, Fort
Lauderdale, FL 33316, Attorney for Plaintiff on this 4'" day of FEBRUARY, 2020.
CONROY SIMBERG
Attorney for Defendant, Edison Insurance Company
125 West Romana Street, Suite 320
Pensacola, FL 32502
Telephone: (850) 436-6605
Facsimile: (850) 436-2102
Primary Email: eservicepns@conroysimberg.com
Secondary Email: cvarner@conroysimberg.com
By: _/s/ Christopher E. Varner
Christopher E. Varner, Esquire
Florida Bar No. 0140147
Document Filed Date
February 04, 2020
Case Filing Date
December 16, 2019
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Filing # 102716179 E-Filed 02/04/2020 01:01:51 PM 1938103 IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO. 19004524CA UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Plaintiff, v. EDISON INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' DISCOVERY REQUESTS Defendant, Edison Insurance Company, by and through its undersigned counsel, moves this Honorable Court for the entry of an Order extending Defendant's time to respond to Plaintiffs’; UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Initial Interrogatories and Request to Produce served with the Complaint, and as grounds therefore, would state as follows: 1. Counsel for Defendant has been unable to fully review Plaintiffs’ Initial Interrogatories and Request to Produce, and respond to same. 2. The Defendant needs additional time in order to fully and properly respond to Plaintiffs' discovery. 3. This motion is not meant to harass or prejudice the Plaintiff(s) or cause any hindrance or delay. 4. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time within which to respond to Plaintiffs' outstanding discovery.CASE NO. 19004524CA 5. The Defendant reserves its right to object to any of Plaintiffs’ discovery requests based on work-product and/or attorney-client privilege or other applicable privilege, protection or immunity from discovery and specifically reserves its right to subsequently raise same. 6. No prejudice will occur to the Plaintiff(s) if an extension of time is granted. WHEREFORE, the Defendant, Edison Insurance Company respectfully requests this Honorable Court grant the Defendant a thirty (30) day extension in which to respond to Plaintiffs’, UNION RESTORATION, INC., a/a/o RAQUEL ESTRADA, Initial Interrogatories and Request to Produce, and/or grant any other relief deemed just and proper. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy hereof has been furnished by service through the eportal to Larry Moskowitz, Esq., Larry Moskowitz, P.A., 400 Southeast 9th Street, Fort Lauderdale, FL 33316, Attorney for Plaintiff on this 4'" day of FEBRUARY, 2020. CONROY SIMBERG Attorney for Defendant, Edison Insurance Company 125 West Romana Street, Suite 320 Pensacola, FL 32502 Telephone: (850) 436-6605 Facsimile: (850) 436-2102 Primary Email: eservicepns@conroysimberg.com Secondary Email: cvarner@conroysimberg.com By: _/s/ Christopher E. Varner Christopher E. Varner, Esquire Florida Bar No. 0140147