`
`IN THE COUNTY COURT IN AND
`FOR BROWARD COUNTY, FLORIDA
`
`PATH MEDICAL LLC A/A/O DANEILIE
`LACEY
`
`CASE NO: COSO-17-000544 (60)
`CIVIL DIVISION
`
`Plaintiff,
`
`VS.
`
`PROGRESSIVE AMERICAN INSURANCE
`
`COMPANY
`
`Defendant.
`
`
`
`MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY
`
`COMES NOW,
`
`the Defendant,
`
`PROGRESSIVE AMERICAN INSURANCE
`
`COMPANY, by and through its undersigned counsel and pursuant to Florida Rules of Civil
`
`Procedure 1.090(b), hereby files this Motion for Extension of Time for Defendant to serve
`
`responses to the discovery served on or about April 7, 2017 (Request for Production, Request for
`
`Admissions,
`
`Interrogatories, Supplemental Request
`
`for Production
`
`re: MPPR_ Edits,
`
`Supplemental Request
`
`for Admission re: 2% Sequestration Reduction, and Supplemental
`
`Interrogatories re: MPPR Edits) and in supportstates as follows:
`
`1. Plaintiff has propounded voluminousdiscovery on the Defendant.
`
`2. The full claim materials are not currently in possession and the defense needs time to
`
`consult with its client in order to prepare discovery responses.
`
`3.
`
`In the event this motion is denied, in an abundance of caution, the Defendant hereby
`
`raises timely objections to each and every request for production and interrogatory on the
`
`groundsthat the information request is overbroad, irrelevant, harassing, seeks disclosure
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK5/4/2017 1:53:13 PM.****
`
`
`
`Case No: COSO-17-000544 (60)
`
`of confidential and/or protected proprietary information, seeks documents protected by
`
`work product and/or documents prepared in anticipation of litigation and is not reasonably
`
`calculated to lead to admissible evidence. The Defendant reserves the right to withdraw
`
`and/or amend these objections.
`
`4. Plaintiff will suffer no prejudice from this extension of time.
`
`WHEREFORE,Defendant, respectfully requests that this Court enter an Order granting
`
`additional time within whichto file responses and amended objections to the Plaintiff's Request
`
`for Production, Request for Admissions, Interrogatories, Supplemental Request for Production
`
`re: MPPR Edits, Supplemental Request for Admission re: 2% Sequestration Reduction, and
`
`Supplemental Interrogatories re: MPPR Edits.
`
`CERTIFICATE OF SERVICE
`
`I HEREBY CERTIFYthat a true and correct copy of the above and foregoing has been
`
`furnished via E-Mail on May 4, 2017 to Todd Landau, Esquire, Landau & Associates, P.A.,
`
`Attorney for Plaintiff, Path Medical, LLC a/a/o Daneilie Lacey, EFilings@PIP-LAWYERS.com,
`
`(954) 744-8383/(954) 391-7805 (F).
`
`Progressive PIP House Counsel
`Attorneys for Defendant
`9675 NW 117 Avenue
`Suite 200
`Medley, FL 33178
`(305) 908-9865 (Asst.)/(305) 908-9856 (Direct)
`Fax: (305) 887-2781
`SERVICE DESIGNATIONS:
`Primary: FLPIPHC-Miami@Progressive.com
`Secondary Shelby_Cohen@Progressive.com
`
`By:/s/ Shelby Cohen
`SHELBY L. COHEN, ESQUIRE
`Florida Bar No. 89789
`“Salaried Employees ofProgressive Casualty Insurance Company”
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
