On August 24, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Jeanette Rau,
Paul Rau,
and
American Integrity Insurance Company Of Florida,
in the District Court of Orange County.
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Filing # 63214642 E-Filed 10/24/2017 12:40:34 AM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR
ORANGE COUNTY, FLORIDA
CIVIL DIVISION
PAUL RAU and JEANNETTE RAU
Plaintiffs, CASE NO.: 2017-CA-7800
-vs-
AMERICAN INTEGRITY INSURANCE
COMPANY OF FLORIDA,
Defendant.
______________________________________/
PLAINTIFFS’ MOTION TO DEEM REQUEST FOR ADMISSIONS
ADMITTED
Plaintiffs, PAUL RAU and JEANETTER RAU (hereinafter “Plaintiffs”), by and
through undersigned counsel, pursuant to Fla. R. Civ. P. 1.370, file this Motion to Deem
Request for Admissions Admitted (hereinafter “Motion”), as follows:
1. Plaintiffs served the Complaint upon Defendant on August 29, 2017. Along with
the Complaint, Plaintiffs filed a Request for Admissions (hereinafter “Written
Discovery”).
2. Therefore, Defendant’s responses to Plaintiffs’ Written Discovery were due on
October 13, 2017.
3. On October 13, 2017, Counsel for Defendant emailed Counsel for Plaintiffs and
asked for an extension of time to respond to Written Discovery. Counsel for
Plaintiffs agreed to the extension. The new due date was October 23, 2017.
4. Despite Counsel for Plaintiffs good-faith extension of time, Defendant failed to
timely respond.
5. Plaintiffs’ Request for Admissions should be deemed admitted as of the date of the
filing of this Motion.
WHEREFORE, the Plaintiffs respectfully request this Honorable Court enter an
Order Deeming Plaintiffs’ Request for Admissions as Admitted. Pursuant to Fla. R. Civ.
P. 1.380(a)(4), Plaintiffs also seek an award of attorney’s fees and costs associated with
this Motion and Hearing.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was filed via
the Florida Courts E-Filing Portal, on October 24, 2017, and served upon All Counsel of
Record.
By: /s/ Jeremy R. Griner
Jeremy R. Griner, P.A.
Jeremy R. Griner, Esquire
FBN: 105179
P: (877) 442-0227
P.O. Box 4408
Tampa, FL 33677
Jeremy@GrinerLegal.com
Document Filed Date
October 24, 2017
Case Filing Date
August 24, 2017
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Filing # 63214642 E-Filed 10/24/2017 12:40:34 AM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVIL DIVISION PAUL RAU and JEANNETTE RAU Plaintiffs, CASE NO.: 2017-CA-7800 -vs- AMERICAN INTEGRITY INSURANCE COMPANY OF FLORIDA, Defendant. ______________________________________/ PLAINTIFFS’ MOTION TO DEEM REQUEST FOR ADMISSIONS ADMITTED Plaintiffs, PAUL RAU and JEANETTER RAU (hereinafter “Plaintiffs”), by and through undersigned counsel, pursuant to Fla. R. Civ. P. 1.370, file this Motion to Deem Request for Admissions Admitted (hereinafter “Motion”), as follows: 1. Plaintiffs served the Complaint upon Defendant on August 29, 2017. Along with the Complaint, Plaintiffs filed a Request for Admissions (hereinafter “Written Discovery”). 2. Therefore, Defendant’s responses to Plaintiffs’ Written Discovery were due on October 13, 2017. 3. On October 13, 2017, Counsel for Defendant emailed Counsel for Plaintiffs and asked for an extension of time to respond to Written Discovery. Counsel for Plaintiffs agreed to the extension. The new due date was October 23, 2017. 4. Despite Counsel for Plaintiffs good-faith extension of time, Defendant failed to timely respond. 5. Plaintiffs’ Request for Admissions should be deemed admitted as of the date of the filing of this Motion. WHEREFORE, the Plaintiffs respectfully request this Honorable Court enter an Order Deeming Plaintiffs’ Request for Admissions as Admitted. Pursuant to Fla. R. Civ. P. 1.380(a)(4), Plaintiffs also seek an award of attorney’s fees and costs associated with this Motion and Hearing. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was filed via the Florida Courts E-Filing Portal, on October 24, 2017, and served upon All Counsel of Record. By: /s/ Jeremy R. Griner Jeremy R. Griner, P.A. Jeremy R. Griner, Esquire FBN: 105179 P: (877) 442-0227 P.O. Box 4408 Tampa, FL 33677 Jeremy@GrinerLegal.com