On December 16, 2019 a
Motion for Extension of Time - to file RESPONSES TO DEFENDANT'S DISCOVERY REQUESTSParty: Plaintiff Mertil, Francky Plaintiff Mertil, Marth
was filed
involving a dispute between
Mertil, Francky,
Mertil, Marth,
and
Citizens Property Insurance Corporation,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 106183272 E-Filed 04/13/2020 04:21:28 PM
FRENCKY MERTIL and MARTH MERTIL, IN THE COUNTY COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
Plaintiffs, BROWARD COUNTY, FLORIDA.
7 CASE NO.: CACE-19-025657
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
” MOTION FOR EXTENSION OF TIME TO FILE
TO DEFENDANT’S DISCOVERY REQUESTS
Plaintiffs, FRENCKY MERTIL and MARTH MERTIL (the “Plaintiffs”), move this Court
for an order extending the time to respond to Defendant’s, CITIZENS PROPERTY INSURANCE
CORPORATION, (the Defendant), discovery requests. In support of this motion the Plaintiffs
state as follows:
1. On or about March 11, 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 (30) 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.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/13/2020 04:21:28 PM.****WHEREFORE, Plaintiffs, FRENCKY MERTIL and MARTH MERTIL, 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: Earleen Cote, Esq. on this 13" day of April 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: Mellawl @mellawyers.com
Secondary Email: Eservice@mellawyers.com
By.___Kaneily A. Valdes ___
Kaneily A. Valdes, Esq.
Florida Bar No. 1003825
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Filing # 106183272 E-Filed 04/13/2020 04:21:28 PM FRENCKY MERTIL and MARTH MERTIL, IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR Plaintiffs, BROWARD COUNTY, FLORIDA. 7 CASE NO.: CACE-19-025657 CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. ” MOTION FOR EXTENSION OF TIME TO FILE TO DEFENDANT’S DISCOVERY REQUESTS Plaintiffs, FRENCKY MERTIL and MARTH MERTIL (the “Plaintiffs”), move this Court for an order extending the time to respond to Defendant’s, CITIZENS PROPERTY INSURANCE CORPORATION, (the Defendant), discovery requests. In support of this motion the Plaintiffs state as follows: 1. On or about March 11, 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 (30) 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. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/13/2020 04:21:28 PM.****WHEREFORE, Plaintiffs, FRENCKY MERTIL and MARTH MERTIL, 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: Earleen Cote, Esq. on this 13" day of April 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: Mellawl @mellawyers.com Secondary Email: Eservice@mellawyers.com By.___Kaneily A. Valdes ___ Kaneily A. Valdes, Esq. Florida Bar No. 1003825