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 # 125978632 E-Filed 04/30/2021 07:10:28 PM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL CIVIL DIVISION
Case No. CACE-20-020926
DAMIAN CAPERA,
Plaintiff,
Vv.
BOARDWALK AT VIZCAYA
CONDOMINIUM ASSOCIATION, INC.,
Defendant.
/
DEFENDANT’S MOTION FOR 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 an
enlargement of time 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 and its responses to
the Discovery are therefore due no later than April 30, 2021.
2. Due to the press of other matters and the need to perform further work and
consultation necessary to prepare Defendant’s responses to the Discovery, Defendant seeks an
enlargement of time of thirty (30) days to respond to the Discovery, including as to any
objections, to and including May 31, 2021.!
3. This Motion is not brought for purposes of harassment or delay and no party will
be prejudiced if this Motion is granted.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/30/2021 07:10:28 PM.****Case No. CACE-20-020926
WHEREFORE, for the foregoing reasons, Defendant respectfully 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 May 31, 2021, and for such
other and further relief as the Court deems just and appropriate.
By:
/s/ Jeffrey F. Bogert
Jeffrey F. Bogert, Esquire
Florida Bar No: 0033601
MCGUINNESS & CICERO
1000 Sawgrass Corporate Parkway, Suite 590
Sunrise, Florida 33323
Telephone: 954-626-5073
Primary E-mail: jeffrey. bogert@mc-atty.com
Dax.dietiker@mc-atty.com
Secondary E-mail: — eservice@dmc-atty.com
laureengerard@mc-atty.com
Attorneys for Boardwalk at Vizcaya Condominium Assoc., Inc.
CERTIFICATE OF SERVICE
I certify that on April 30, 2021, I electronically filed 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.
MILITZOK & ASSOCIATES, P.A. D/B/A
THE MOLD LAWYERS
3230 Stirling Road
Hollywood, Florida 33021
mjm@malawfl.com
nathalie@malawfl.com
service@malawfl.com
Counsel for Plaintiff, Damian Capera
Humberto Rubio, Esq.
LAW FIRM OF RUBIO & ASSOCIATES, PA
8950 SW 74 Ct, Suite 1804
Miami, Florida 33156
hrubio@rubiolegal.com
Counsel for Defendant, Boardwalk at Vizcaya
Condominium Association, Inc.
By: /s/Jeffrey F. Bogert
Jeffrey F. Bogert, Esquire
Florida Bar No: 0033601
1 May 30, 2021 is a Sunday.
Document Filed Date
April 30, 2021
Case Filing Date
December 14, 2020
Category
Condominium Action
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Filing # 125978632 E-Filed 04/30/2021 07:10:28 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL CIVIL DIVISION Case No. CACE-20-020926 DAMIAN CAPERA, Plaintiff, Vv. BOARDWALK AT VIZCAYA CONDOMINIUM ASSOCIATION, INC., Defendant. / DEFENDANT’S MOTION FOR 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 an enlargement of time 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 and its responses to the Discovery are therefore due no later than April 30, 2021. 2. Due to the press of other matters and the need to perform further work and consultation necessary to prepare Defendant’s responses to the Discovery, Defendant seeks an enlargement of time of thirty (30) days to respond to the Discovery, including as to any objections, to and including May 31, 2021.! 3. This Motion is not brought for purposes of harassment or delay and no party will be prejudiced if this Motion is granted. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/30/2021 07:10:28 PM.****Case No. CACE-20-020926 WHEREFORE, for the foregoing reasons, Defendant respectfully 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 May 31, 2021, and for such other and further relief as the Court deems just and appropriate. By: /s/ Jeffrey F. Bogert Jeffrey F. Bogert, Esquire Florida Bar No: 0033601 MCGUINNESS & CICERO 1000 Sawgrass Corporate Parkway, Suite 590 Sunrise, Florida 33323 Telephone: 954-626-5073 Primary E-mail: jeffrey. bogert@mc-atty.com Dax.dietiker@mc-atty.com Secondary E-mail: — eservice@dmc-atty.com laureengerard@mc-atty.com Attorneys for Boardwalk at Vizcaya Condominium Assoc., Inc. CERTIFICATE OF SERVICE I certify that on April 30, 2021, I electronically filed 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. MILITZOK & ASSOCIATES, P.A. D/B/A THE MOLD LAWYERS 3230 Stirling Road Hollywood, Florida 33021 mjm@malawfl.com nathalie@malawfl.com service@malawfl.com Counsel for Plaintiff, Damian Capera Humberto Rubio, Esq. LAW FIRM OF RUBIO & ASSOCIATES, PA 8950 SW 74 Ct, Suite 1804 Miami, Florida 33156 hrubio@rubiolegal.com Counsel for Defendant, Boardwalk at Vizcaya Condominium Association, Inc. By: /s/Jeffrey F. Bogert Jeffrey F. Bogert, Esquire Florida Bar No: 0033601 1 May 30, 2021 is a Sunday.