On July 28, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Barrata, Daniel J,
Helms, Stacey L,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 133225999 E-Filed 08/23/2021 03:56:22 PM
2152302
IN THE CIRCUIT COURT OF THE 14TH JUDICIAL
CIRCUIT IN AND FOR BAY COUNTY, FLORIDA
CASE NO. 21000941CA
STACEY L. HELMS and DANIEL J. BARRATA,
as Trustees of the WILLIAM E. CRAWFORD
REVOCABLE TRUST,
Plaintiffs,
Vv.
EDISON INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFFS'COMPLAINT
Defendant, Edison Insurance Company, by and through the undersigned counsel,
files this Motion for Extension of Time to Respond to Plaintiffs’, STACEY L. HELMS and
DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE
TRUST, Complaint and as grounds therefore would state:
1. The undersigned counsel was recently retained to represent the interest of
the Defendant.
2. The Defendant needs additional time in order to fully and properly respond
to Plaintiffs' Complaint.
3. Florida Rule of Civil Procedure 1.090(b) allows this Court to extend the time
within which to respond to Plaintiffs’ Complaint.
4. This Motion is not made for purposes of delay or avoidance, but to allow
Defendant to a serve complete, accurate and proper response to Plaintiffs' Complaint.CASE NO. 21000941CA
5. As such, there would be no prejudice to Plaintiff(s), in allowing Defendant
additional time as requested herein.
WHEREFORE, the Defendant, Edison Insurance Company, respectfully requests
this Honorable Court grant the Defendant a twenty (20) day extension in which to respond
to Plaintiffs’, STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM
E. CRAWFORD REVOCABLE TRUST, Complaint and/or grant any other relief deemed
just and proper.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy of the foregoing has been served on all Counsel
of Record via the Florida E-Filing Portal this 23 day of _ August , 2021.
CONROY SIMBERG
Attorney for Defendant, Edison Insurance Company
1801 Centrepark Drive East, Suite 200
West Palm Beach, FL 33401
Telephone: 561-697-8088
Facsimile: 561-697-8664
Primary Email: eservicewpb@conroysimberg.com
Secondary Email: rhorwitz@conroysimberg.com
By: _/s/ Robert S. Horwitz
Robert S. Horwitz, Esquire
Florida Bar No. 149454
Document Filed Date
August 23, 2021
Case Filing Date
July 28, 2021
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Filing # 133225999 E-Filed 08/23/2021 03:56:22 PM 2152302 IN THE CIRCUIT COURT OF THE 14TH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO. 21000941CA STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE TRUST, Plaintiffs, Vv. EDISON INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS'COMPLAINT Defendant, Edison Insurance Company, by and through the undersigned counsel, files this Motion for Extension of Time to Respond to Plaintiffs’, STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE TRUST, Complaint and as grounds therefore would state: 1. The undersigned counsel was recently retained to represent the interest of the Defendant. 2. The Defendant needs additional time in order to fully and properly respond to Plaintiffs' Complaint. 3. Florida Rule of Civil Procedure 1.090(b) allows this Court to extend the time within which to respond to Plaintiffs’ Complaint. 4. This Motion is not made for purposes of delay or avoidance, but to allow Defendant to a serve complete, accurate and proper response to Plaintiffs' Complaint.CASE NO. 21000941CA 5. As such, there would be no prejudice to Plaintiff(s), in allowing Defendant additional time as requested herein. WHEREFORE, the Defendant, Edison Insurance Company, respectfully requests this Honorable Court grant the Defendant a twenty (20) day extension in which to respond to Plaintiffs’, STACEY L. HELMS and DANIEL J. BARRATA, as Trustees of the WILLIAM E. CRAWFORD REVOCABLE TRUST, Complaint and/or grant any other relief deemed just and proper. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy of the foregoing has been served on all Counsel of Record via the Florida E-Filing Portal this 23 day of _ August , 2021. CONROY SIMBERG Attorney for Defendant, Edison Insurance Company 1801 Centrepark Drive East, Suite 200 West Palm Beach, FL 33401 Telephone: 561-697-8088 Facsimile: 561-697-8664 Primary Email: eservicewpb@conroysimberg.com Secondary Email: rhorwitz@conroysimberg.com By: _/s/ Robert S. Horwitz Robert S. Horwitz, Esquire Florida Bar No. 149454