On October 15, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Villeda , Jesus,
Villeda , Jhaneth,
and
Citizens Property Insurance Corporation,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 112777301 E-Filed 09/02/2020 12:47:31 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
JESUS VILLEDA and JHANETH VILLEDA,
Plaintiffs,
v. CASE NUMBER: CACE-19-021344
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant. /
DEFENDANT’S MOTION TO COMPEL DISCOVERY RESPONSES
COMES NOW Defendant Citizens Property Insurance Corporation, hereinafter
“Citizens” or “Defendant”, by and through its undersigned counsel, and motions this Court to
compel Plaintiffs to respond to Defendant’s discovery requests and, in support thereof, states:
1. This is an action for an alleged breach of an insurance contract.
2. Defendant served its Request for Production and Interrogatories on Plaintiffs on April
21, 2020.
3. Plaintiff has not filed a Motion for Extension of Time to respond to discovery requests.
4. Defendant has made several requests to Plaintiff to obtain responses.
5. To date, Plaintiff has failed to respond to written discovery requests.
6. Plaintiff's lack of response to written discovery requests has prejudiced Defendant by
not allowing it to obtain information needed to defend its position.
WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully
requests this Court grant the Defendant’s Motion to Compel Discovery Responses by ordering
Plaintiffs to respond Defendant’s discovery requests and grant Defendant any and all other relief
that the Court deems just and proper.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/02/2020 12:47:30 PM.****CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been provided
via electronic correspondence to: Annette Del Aguila, Esq. at eservice@mellawyers.com and
mellaw7@mellawyers.com, on this 2nd day of September, 2020.
RUBINTON SIMMS, P.A.
3440 Hollywood Blvd, Suite 460
Hollywood, Florida 33021
Telephone: 954-251-5500
Fax: 954-251-5501
By: /s/Vida Gasactis
JEFFREY A. RUBINTON, ESQ.
Florida Bar: 821756
VIDA E. JASAITIS, ESQ.
Florida Bar: 245800
Primary E-Mail: vjasaitis@rubintonlaw.com
Secondary E-Mail: vprzewoznik@rubintonlaw.com
Document Filed Date
September 02, 2020
Case Filing Date
October 15, 2019
Category
Contract and Indebtedness
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Filing # 112777301 E-Filed 09/02/2020 12:47:31 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. JESUS VILLEDA and JHANETH VILLEDA, Plaintiffs, v. CASE NUMBER: CACE-19-021344 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT’S MOTION TO COMPEL DISCOVERY RESPONSES COMES NOW Defendant Citizens Property Insurance Corporation, hereinafter “Citizens” or “Defendant”, by and through its undersigned counsel, and motions this Court to compel Plaintiffs to respond to Defendant’s discovery requests and, in support thereof, states: 1. This is an action for an alleged breach of an insurance contract. 2. Defendant served its Request for Production and Interrogatories on Plaintiffs on April 21, 2020. 3. Plaintiff has not filed a Motion for Extension of Time to respond to discovery requests. 4. Defendant has made several requests to Plaintiff to obtain responses. 5. To date, Plaintiff has failed to respond to written discovery requests. 6. Plaintiff's lack of response to written discovery requests has prejudiced Defendant by not allowing it to obtain information needed to defend its position. WHEREFORE, Defendant, Citizens Property Insurance Corporation, respectfully requests this Court grant the Defendant’s Motion to Compel Discovery Responses by ordering Plaintiffs to respond Defendant’s discovery requests and grant Defendant any and all other relief that the Court deems just and proper. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/02/2020 12:47:30 PM.****CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been provided via electronic correspondence to: Annette Del Aguila, Esq. at eservice@mellawyers.com and mellaw7@mellawyers.com, on this 2nd day of September, 2020. RUBINTON SIMMS, P.A. 3440 Hollywood Blvd, Suite 460 Hollywood, Florida 33021 Telephone: 954-251-5500 Fax: 954-251-5501 By: /s/Vida Gasactis JEFFREY A. RUBINTON, ESQ. Florida Bar: 821756 VIDA E. JASAITIS, ESQ. Florida Bar: 245800 Primary E-Mail: vjasaitis@rubintonlaw.com Secondary E-Mail: vprzewoznik@rubintonlaw.com