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`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`CIRCUIT CIVIL
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`MEIBEL SABOYA DIAZ,
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`PLAINTIFF,
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` Case No: 2023 CA 000499
`VS.
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`SEAWORLD PARKS &
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`ENTERTAINMENT
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`LLC D/B/A BUSCH GARDENS,
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`DEFENDANT.
`___________________________________________/
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`MOTION TO ENLARGE TIME TO RESPOND TO DISCOVERY
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`Comes now Plaintiff, by and through the undersigned counsel, and hereby files this motion
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`to enlarge time to respond to the discovery from Defendant, in accordance with Fla. R. Civ. Pro.
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`1.090, and states as follows:
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`1.
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`Florida Rules of Civil Procedure 1.090 permits the court to enlarge time to respond to
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`discovery upon request of a party, for cause shown, or if after the due date, excusable neglect.
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`2.
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`Defendant served discovery upon Plaintiff, and for the following reason, Plaintiff has been
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`unable to respond to the discovery: Unprecedented changes have been made to the tort law in
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`Florida, and Plaintiff’s counsel’s office was forced to file more lawsuits over a course of a couple
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`of weeks than ever before in the history of counsel’s office (see HB 837).
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`3.
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`All staff helped, including the litigation manager returning from maternity leave early and
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`filing lawsuits with her baby in her arms.
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`4.
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`5.
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`As such, Plaintiff’s counsel was physically unable to meet the deadlines in this case.
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`Further, Plaintiff’s counsel did send the interrogatories to the Plaintiff to be signed, but
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`counsel has not received the notarized version back from the Plaintiff. As of the date of this
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`1
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`motion, the Interrogatories and Request for production responses are being served to Defendant,
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`just without the interrogatories being notarized.
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`6.
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`Plaintiff hereby is requesting additional days to respond to the discovery and provide
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`notarized interrogatory page.
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`WHEREFORE, Plaintiff requests that this Court issue an order enlarging the time for
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`Plaintiff to respond to Defendant’s discovery, and any other remedy that this Court deems just and
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`proper.
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`CERTIFICATE OF SERVICE
`I HEREBY CERTIFY that a true and correct copy of the foregoing document has been
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`furnished on March 31, 2023, by Electronic Mail in accordance with Fla. R. Jud. Admin. 2.516,
`or in accordance with the relevant applicable Florida Rule of Civil Procedure, to the referenced
`party at the following designated email service address(es):
`Carie L. Hall, Esq.
`Robert L. Blank, Esq.
`Ryan S. Brown, Esq.
`Rumberger, Kirk & Caldwell, P.A.
`100 North Tampa Street, Ste. 2000
`Post Office Box 3390
`Tampa, Florida 33601-3390
`rblanksecy@rumberger.com
`docketingtpa@rumberger.com
`chall@rumberger.com
`challsecy@rumberger.com
`rbrown@rumberger.com
`rbrownsecy@rumberger.com
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`Dated March 31, 2023.
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`Respectfully Submitted,
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`_____________________________
`Amy Kimberly Kenyon, Esq.
`Florida Bar No.: 73526
`Amy@kenyonlawfirm.com
`Kenyon Law Group, PLLC
`1215 Manatee Avenue West, Ste. 105
`Bradenton, Florida, 34205
`(941) 894-1234 phone
`E-serve: eservice@kenyonlawfirm.com
`Attorney for Plaintiff
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`2
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