On January 04, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Vigo, Gisela,
Vigo, Martin,
and
Universal Property And Casualty Insurance Company,
for Contract & Indebtedness
in the District Court of Miami-Dade County.
Preview
Filing # 109898578 E-Filed 07/07/2020 04:14:42 PM
MARTIN VIGO and GISELA VIGO, IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR
Plaintiff, MIAMI-DADE COUNTY, FLORIDA
v.
CASE NO.: 2019-000312-CA-01
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
PLAINTIFFS’ SECOND MOTION FOR EXTENSION OF TIME TO FILE
RESPONSES TO DEFENDANT’S DISCOVERY REQUESTS
Plaintiffs, MARTIN VIGO and GISELA VIGO, (the “Plaintiffs”), move this Court for an
order extending the time to respond to Defendant’s, HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY’s, (the Defendant), discovery requests. In support of this motion the
Plaintiffs state as follows:
1. On or about May 6th, 2020; Plaintiffs were served with Defendant’s Discovery
Requests.
2. Due to scheduling conflicts of the insureds and the undersigned, the undersigned
seeks an additional thirty (20) days in which to adequately respond to the Defendant’s discovery
requests.
3. Plaintiffs are not seeking to extend any other deadlines.
4. An extension of time for the requested deadline will be sufficient to adequately file
responses to the Defendant’s discovery requests.
5. Furthermore, an extension of the deadline will not prejudice either party.
WHEREFORE, Plaintiffs, MARTIN VIGO and GISELA VIGO, respectfully request that
this Court enter an Order granting this Motion to Extend the time in which to file their responses
to Defendant’s discovery request, and for any further relief this Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via
Florida E Filing Portal to: Matthew P. Strauss, Esq. on this 7th day of July, 2020.
Marin, Eljaiek, Lopez & Martinez P.L.
Counsel for the Insured
2601 South Bayshore Drive, 18th Floor
Coconut Grove, Florida 33133
Telephone No. (305) 444-5969
Facsimile No. (305) 444-1939
Email: Mellaw2@mellawyers.com
By: /s/ Joanna M. Alemany
Joanna M. Alemany, Esq.
Florida Bar No. 71375
JMA@mellawyers.com
Natasha A. Rivera, Esq.
Florida Bar No. 1015700
NRivera@mellawyers.com
Document Filed Date
July 07, 2020
Case Filing Date
January 04, 2019
Category
Contract & Indebtedness
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Filing # 109898578 E-Filed 07/07/2020 04:14:42 PM MARTIN VIGO and GISELA VIGO, IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR Plaintiff, MIAMI-DADE COUNTY, FLORIDA v. CASE NO.: 2019-000312-CA-01 UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / PLAINTIFFS’ SECOND MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO DEFENDANT’S DISCOVERY REQUESTS Plaintiffs, MARTIN VIGO and GISELA VIGO, (the “Plaintiffs”), move this Court for an order extending the time to respond to Defendant’s, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY’s, (the Defendant), discovery requests. In support of this motion the Plaintiffs state as follows: 1. On or about May 6th, 2020; Plaintiffs were served with Defendant’s Discovery Requests. 2. Due to scheduling conflicts of the insureds and the undersigned, the undersigned seeks an additional thirty (20) days in which to adequately respond to the Defendant’s discovery requests. 3. Plaintiffs are not seeking to extend any other deadlines. 4. An extension of time for the requested deadline will be sufficient to adequately file responses to the Defendant’s discovery requests. 5. Furthermore, an extension of the deadline will not prejudice either party. WHEREFORE, Plaintiffs, MARTIN VIGO and GISELA VIGO, respectfully request that this Court enter an Order granting this Motion to Extend the time in which to file their responses to Defendant’s discovery request, and for any further relief this Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Florida E Filing Portal to: Matthew P. Strauss, Esq. on this 7th day of July, 2020. Marin, Eljaiek, Lopez & Martinez P.L. Counsel for the Insured 2601 South Bayshore Drive, 18th Floor Coconut Grove, Florida 33133 Telephone No. (305) 444-5969 Facsimile No. (305) 444-1939 Email: Mellaw2@mellawyers.com By: /s/ Joanna M. Alemany Joanna M. Alemany, Esq. Florida Bar No. 71375 JMA@mellawyers.com Natasha A. Rivera, Esq. Florida Bar No. 1015700 NRivera@mellawyers.com