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Filing# 139408712 E-Filed 1 1/30/2021 08:09:36 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL CIVIL DIVISION
Case No. CACE-20-020926
DAMIAN CAPERA,
Plaintiff.
V
BOARDWALK
AT
VIZCAYA
CONDOMINIUM ASSOCIATION, INC.,
Defendant.
i
DEFENDANT'S MOTION FOR FURTHER ENLARGEMENT OF
TIME TO RESPOND TO DISCOVERY
Defendant, BOARDWALK AT VIZCAYA CONDOMINIUM ASSOCIATION, INC.
("Defendant"),pursuant to the Florida Rules of Civil Procedure, hereby moves for a further
enlargementoftime to respond to Plaintiff,
DAMIAN CAPERA'S ("Plaintiff'),
First Request for
Production and First Set of Interrogatories
(collectively,
the "Discovery") served on Defendant in
this action,and as grounds states:
1.
Defendant was served with the Discovery on March 31, 2021.
2.
Defendant timely filed motions for enlargement of time to respond to the
Discovery,includingas to any objections.Pursuant to the Agreed Order on Defendant Boardwalk
at Vizcaya Condominium Association,Inc.' s Motion for Further Enlargement of Time to Respond
to Discovery dated November 9,2021, the responses, includingas to any objections,are currently
due on December 1,2021.
3
Due to the need to perform further work and consultation necessary to prepare
Defendant' s responses to the Discovery,Defendant seeks a further enlargementof time of fifteen
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 08:09:36 PM.****
(15)days to respond to the Discovery,includingas to any objections,
to and includingDecember
16,2021.
4.
This Motion is not brought for purposes of harassment or delay and no party will
be prejudicedifthis Motion is granted.
WHEREFORE, for the foregoingreasons, Defendant respectfullyrequests the entry ofan
order grantingthis motion and providing Defendant an additional fifteen (15) days to respond to
the Discovery,includingas to any objections,
to and includingDecember 16, 2021, and for such
other and further relief as the Court deems justand appropriate.
By:
INJMy F.Bogert
JeffreyF. Bogert,Esquire
Florida Bar No: 0033601
MCGUINNESS & CICERO
1000 Sawgrass CorporateParkway, Suite 590
Sunrise,Florida 33323
Telephone: 954-626-5073
Primary E-mail:
jeffrey.bogert@mc-ate.
com
Dax.dietiker@mc-ate.com
Secondary E-mail:
eservice@dmc-atty.com
laureengerard@mc-atty.
com
Attorneysfor Boardwalk at Vizcaya Condominium
Assoc.,Inc.
2
CERTIFICATE OF SERVICE
I certifythat on November 30,2021, I electronically
filed the foregoingdocument through
the Florida Courts E-FilingPortal and that the Portal was used as a means of service of this
document on this day by email upon:
Matthew J. Militzok. Esq.
Humberto Rubio, Esq.
MILITZOK & ASSOCIATES, P.A. D/B/A
LAW FIRM OF RUBIO & ASSOCIATES, PA
THE MOLD LAWYERS
8950 SW 74 Ct, Suite 1804
3230 StirlingRoad
Miami, Florida 33156
Hollywood, Florida 33021
hrubio@rubiolegal.com
mjm@malawfl.com
service@malawfl.com
CounselM Defendant, Boardwalk at Vizcaya
Counsel for Plaintiff,
Damian Capera
Condominium Association, Inc.
By: /s/Jeffrey
F. Bogert
JeffreyF. Bogert, Esquire
Florida Bar No: 0033601
3
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Filing# 139408712 E-Filed 1 1/30/2021 08:09:36 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL CIVIL DIVISION Case No. CACE-20-020926 DAMIAN CAPERA, Plaintiff. V BOARDWALK AT VIZCAYA CONDOMINIUM ASSOCIATION, INC., Defendant. i DEFENDANT'S MOTION FOR FURTHER ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY Defendant, BOARDWALK AT VIZCAYA CONDOMINIUM ASSOCIATION, INC. ("Defendant"),pursuant to the Florida Rules of Civil Procedure, hereby moves for a further enlargementoftime to respond to Plaintiff, DAMIAN CAPERA'S ("Plaintiff'), First Request for Production and First Set of Interrogatories (collectively, the "Discovery") served on Defendant in this action,and as grounds states: 1. Defendant was served with the Discovery on March 31, 2021. 2. Defendant timely filed motions for enlargement of time to respond to the Discovery,includingas to any objections.Pursuant to the Agreed Order on Defendant Boardwalk at Vizcaya Condominium Association,Inc.' s Motion for Further Enlargement of Time to Respond to Discovery dated November 9,2021, the responses, includingas to any objections,are currently due on December 1,2021. 3 Due to the need to perform further work and consultation necessary to prepare Defendant' s responses to the Discovery,Defendant seeks a further enlargementof time of fifteen *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/30/2021 08:09:36 PM.**** (15)days to respond to the Discovery,includingas to any objections, to and includingDecember 16,2021. 4. This Motion is not brought for purposes of harassment or delay and no party will be prejudicedifthis Motion is granted. WHEREFORE, for the foregoingreasons, Defendant respectfullyrequests the entry ofan order grantingthis motion and providing Defendant an additional fifteen (15) days to respond to the Discovery,includingas to any objections, to and includingDecember 16, 2021, and for such other and further relief as the Court deems justand appropriate. By: INJMy F.Bogert JeffreyF. Bogert,Esquire Florida Bar No: 0033601 MCGUINNESS & CICERO 1000 Sawgrass CorporateParkway, Suite 590 Sunrise,Florida 33323 Telephone: 954-626-5073 Primary E-mail: jeffrey.bogert@mc-ate. com Dax.dietiker@mc-ate.com Secondary E-mail: eservice@dmc-atty.com laureengerard@mc-atty. com Attorneysfor Boardwalk at Vizcaya Condominium Assoc.,Inc. 2 CERTIFICATE OF SERVICE I certifythat on November 30,2021, I electronically filed the foregoingdocument through the Florida Courts E-FilingPortal and that the Portal was used as a means of service of this document on this day by email upon: Matthew J. Militzok. Esq. Humberto Rubio, Esq. MILITZOK & ASSOCIATES, P.A. D/B/A LAW FIRM OF RUBIO & ASSOCIATES, PA THE MOLD LAWYERS 8950 SW 74 Ct, Suite 1804 3230 StirlingRoad Miami, Florida 33156 Hollywood, Florida 33021 hrubio@rubiolegal.com mjm@malawfl.com service@malawfl.com CounselM Defendant, Boardwalk at Vizcaya Counsel for Plaintiff, Damian Capera Condominium Association, Inc. By: /s/Jeffrey F. Bogert JeffreyF. Bogert, Esquire Florida Bar No: 0033601 3