On December 14, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Capera, Damian,
and
Boardwalk At Bizcaya Condominium Association,
for Condominium Action
in the District Court of Broward County.
Preview
Filing# 137664802 E-Filed 1 1/01/2021 04:10:04 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 AMENDED 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.The responses, includingas to any objections,are
currentlydue on November 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 thirty
(30) days to respond to the Discovery,includingas to any objections,to and includingDecember
1,2021.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/01/2021 04:10:04 PM.****
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 providingDefendant an additional thirty(30) days to respond to
the Discovery,includingas to any objections,to and includingDecember 1, 2021, and for such
other and further relief as the Court deems justand appropriate.
By-
/s/Je/MF.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 1,2021, 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
Document Filed Date
November 01, 2021
Case Filing Date
December 14, 2020
Category
Condominium Action
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