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Filing # 131882124 E-Filed 08/02/2021 05:48:42 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.
'
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
enlargement oftime 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, including as to any objections. The responses, including as to any objections, are
currently due on August 2,2021.
3
Due to the need to perform further work and consultation necessary to prepare
Defendant's responses to the Discovery, Defendant seeks a further enlargement of time of thirty
(30) days to respondto the Discovery,including as to any objections, to and including September
1,2021.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 05:48:42 PM.****
4.
This Motion is not brought for purposes of harassmentor delay and no party will
be prejudiced if this Motion is granted.
WHEREFORE, for the foregoing reasons, Defendantrespectfully requests the entry of an
order granting this motion and providing Defendant an additional thirty (30) days to respond to
the Discovery, including as to any objections, to and including September 1, 2021, and for such
other and further relief as the Court deemsjust and appropriate.
By-
Is/Mevf.Bogert
Jeffrey F. Bogert, Esquire
FloridaBar No: 0033601
MCGUINNESS & CICERO
1000 Sawgrass Corporate Parkway, Suite 590
Sunrise, Florida 33323
Telephone: 954-626-5073
Primary E-mail:
com
Secondary E-mail:
Attorneysfor Boardwalkat Vizcaya Condominium
Assoc.,Inc.
2
CERTIFICATE OF SERVICE
I certify that on August 2,2021, I electronicallyfiled the foregoing document through the
Florida Courts E-Filing Portal 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 Stirling Road
Miami, Florida 33156
Hollywood, Florida 33021
mjm@malawfl.com
service@malawfl.com
CounselM Defendant, Boardwalk at Vizcaya
Counselfor Plaintiff, Damian Capera
Condominium Association,Inc.
By: /s/Jeffrey F. Bogert
Jeffrey F. Bogert, Esquire
Florida Bar No: 0033601
3
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Filing # 131882124 E-Filed 08/02/2021 05:48:42 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. ' 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 enlargement oftime 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, including as to any objections. The responses, including as to any objections, are currently due on August 2,2021. 3 Due to the need to perform further work and consultation necessary to prepare Defendant's responses to the Discovery, Defendant seeks a further enlargement of time of thirty (30) days to respondto the Discovery,including as to any objections, to and including September 1,2021. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/02/2021 05:48:42 PM.**** 4. This Motion is not brought for purposes of harassmentor delay and no party will be prejudiced if this Motion is granted. WHEREFORE, for the foregoing reasons, Defendantrespectfully requests the entry of an order granting this motion and providing Defendant an additional thirty (30) days to respond to the Discovery, including as to any objections, to and including September 1, 2021, and for such other and further relief as the Court deemsjust and appropriate. By- Is/Mevf.Bogert Jeffrey F. Bogert, Esquire FloridaBar No: 0033601 MCGUINNESS & CICERO 1000 Sawgrass Corporate Parkway, Suite 590 Sunrise, Florida 33323 Telephone: 954-626-5073 Primary E-mail: com Secondary E-mail: Attorneysfor Boardwalkat Vizcaya Condominium Assoc.,Inc. 2 CERTIFICATE OF SERVICE I certify that on August 2,2021, I electronicallyfiled the foregoing document through the Florida Courts E-Filing Portal 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 Stirling Road Miami, Florida 33156 Hollywood, Florida 33021 mjm@malawfl.com service@malawfl.com CounselM Defendant, Boardwalk at Vizcaya Counselfor Plaintiff, Damian Capera Condominium Association,Inc. By: /s/Jeffrey F. Bogert Jeffrey F. Bogert, Esquire Florida Bar No: 0033601 3