On October 18, 2019 a
Motion for Extension of Time - TO RESPOND TO PLAINTIFF'S AMENDED DISCOVERYParty: Defendant Depeine, John
was filed
involving a dispute between
Thomas, Katina,
and
Depeine, John,
for Auto Negligence
in the District Court of Broward County.
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Filing # 100384051 E-Filed 12/16/2019 03:54:31 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
KATINA THOMAS,
Plaintiff,
vs. CASE NO.: 19-021558 (05)
JOHN DEPEINE
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S AMENDED DISCOVERY
Defendant JOHN DEPEINE (“DEPEINE”) by and through undersigned counsel hereby
moves for an enlargement of time within which to serve its responses to Interrogatories, Request
for Production and Request for Admissions, and in support states as follows:
1. DEPEINE’s responses to Plaintiff's Interrogatories, Request for Production and
Request for Admissions are due on December 16, 2019.
2. Due to the press of other deadlines, the undersigned counsel seeks additional time
to adequately prepare its responses.
3. This request is being filed in good faith and not for the purpose of unnecessary
delay.
WHEREFORE, Defendant, JOHN DEPEINE, respectfully requests the Court to enter an
order extending the time within which Defendant, JOHN DEPEINE may file its responses to
Plaintiff's Interrogatories, Request for Production and Request for Admissions.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/16/2019 03:54:31 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the
Clerk of Court and via Florida e-Filing Portal to the following, this_16"_ day of December,
2019.
Kevin B. Dennis, Esquire
Thomas & Pearl, P.A.
2404 NE 9" Street
Ft. Lauderdale, Florida 33304
TEL: 954-563-9224
FAX: 954-563-9497
litdept@thomaspearl.com
(Counsel for Plaintiff)
128979771
s/ Erik Perez
SCOTT M. SARASON
Florida Bar No.: 0394718
E-mail: ssarason@rumberger.com (primary)
docketingMiami@rumberger.com and
ssarasonsecy@rumberger.com (secondary)
DOUGLAS E. EDE
Florida Bar No.: 764787
E-mail: dede@rumberger.com (primary)
docketmiami@rumberger.com
dedesecy@rumberger.com (secondary)
ERIK A. PEREZ
Florida Bar No.: 115564
E-mail: eperez@rumberger.com
docketingmiami@rumberger.com and
eperezsecy@rumberger.com
Rumberger, Kirk, & Caldwell, P.A.
A Professional Association
Brickell City Tower, Suite 3000
80 Southwest 8th Street
Miami, Florida 33130-3037
Tel: 305.358.5577
Fax: 305.371.7580
Attorneys for Defendant
Document Filed Date
December 16, 2019
Case Filing Date
October 18, 2019
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Filing # 100384051 E-Filed 12/16/2019 03:54:31 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA KATINA THOMAS, Plaintiff, vs. CASE NO.: 19-021558 (05) JOHN DEPEINE Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S AMENDED DISCOVERY Defendant JOHN DEPEINE (“DEPEINE”) by and through undersigned counsel hereby moves for an enlargement of time within which to serve its responses to Interrogatories, Request for Production and Request for Admissions, and in support states as follows: 1. DEPEINE’s responses to Plaintiff's Interrogatories, Request for Production and Request for Admissions are due on December 16, 2019. 2. Due to the press of other deadlines, the undersigned counsel seeks additional time to adequately prepare its responses. 3. This request is being filed in good faith and not for the purpose of unnecessary delay. WHEREFORE, Defendant, JOHN DEPEINE, respectfully requests the Court to enter an order extending the time within which Defendant, JOHN DEPEINE may file its responses to Plaintiff's Interrogatories, Request for Production and Request for Admissions. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/16/2019 03:54:31 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was served by e-Filing with the Clerk of Court and via Florida e-Filing Portal to the following, this_16"_ day of December, 2019. Kevin B. Dennis, Esquire Thomas & Pearl, P.A. 2404 NE 9" Street Ft. Lauderdale, Florida 33304 TEL: 954-563-9224 FAX: 954-563-9497 litdept@thomaspearl.com (Counsel for Plaintiff) 128979771 s/ Erik Perez SCOTT M. SARASON Florida Bar No.: 0394718 E-mail: ssarason@rumberger.com (primary) docketingMiami@rumberger.com and ssarasonsecy@rumberger.com (secondary) DOUGLAS E. EDE Florida Bar No.: 764787 E-mail: dede@rumberger.com (primary) docketmiami@rumberger.com dedesecy@rumberger.com (secondary) ERIK A. PEREZ Florida Bar No.: 115564 E-mail: eperez@rumberger.com docketingmiami@rumberger.com and eperezsecy@rumberger.com Rumberger, Kirk, & Caldwell, P.A. A Professional Association Brickell City Tower, Suite 3000 80 Southwest 8th Street Miami, Florida 33130-3037 Tel: 305.358.5577 Fax: 305.371.7580 Attorneys for Defendant