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Filing # 121722939 E-Filed 02/19/2021 01:52:50 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY,
FLORIDA
Case No.: CACE-20-017981
CARLOS A. OSPINA and DIANE J.
OSPINA,
Plaintiff,
vs.
AIDA FONSECA and TRAVELERS
PERSONAL INSURANCE COMPANY, a
Connecticut corporation,
Defendants.
/
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO PERFECT
PROCESS AND SERVICE OF PROCESS ON DEFENDANTS, AIDA FONSECA and
TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation
Plaintiffs, CARLOS A. OSPINA and DIANE J. OSPINA, by and through their undersigned
counsel, hereby file this Motion for Extension of Time to Perfect Process and Service of Process on
Defendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a
Connecticut corporation, and in support thereof state:
1. That a lawsuit was filed in this action on October 28, 2020.
2. That a Summons issued on the Defendant, AIDA FONSECA, was forwarded with
the Complaint, Request for Admissions, Request for Production, Notice of Service of
Interrogatories, and Interrogatories, to Magic Process, LLC, for service on said Defendant.
3. That Jenna Guthrie of Magic Process, LLC, has advised that after four attempts to
serve the Defendant, AIDA FONSECA, at 4147 Stirling Road, Apt. 502, Davie, Florida 33314, it
has been determined and confirmed by her apartment complex office that she no longer resides at
said address.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/19/2021 01:52:50 PM.****4. That Jay Bowen of Magic Process, LLC, advised that upon investigation, the
Defendant, AIDA FONSECA, was believed to be living at 4820 SW 47" Lane, Davie, Florida
33314-4649,
5. That Jenna Guthrie of Magic Process, LLC, has advised that an attempt to serve the
Defendant, AIDA FONSECA, at 4820 SW 47" Lane, Davie, Florida 33314-4649, resulted in the
process server being advised that AIDA FONSECA does not reside at that address.
6. That Magic Process, LLC, is presently investigating and attempting to locate the
Defendant, AIDA FONSECA.
7. That a Summons issued on the Defendant, TRAVELERS PERSONAL
INSURANCE COMPANY, a Connecticut corporation, was forwarded with the Complaint,
Request for Admissions, Request for Production, Notice of Service of Interrogatories, and
Interrogatories, to the Chief Financial Officer, Department of Financial Services, 200 E. Gaines
Street, Tallahassee, Florida 32399, for service on said Defendant.
8. That the Summons forwarded to the Chief Financial Officer, Department of
Financial Services, 200 E. Gaines Street, Tallahassee, Florida 32399, was not accepted and
returned non-served with an indication that The Department of Financial Services is not the agent
for TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation.
9. That an Alias Summons on the Defendant, TRAVELERS PERSONAL
INSURANCE COMPANY, a Connecticut corporation, has been issued and forwarded for service
upon said Defendant’s registered agent, Corporation Service Company, as listed with the Division
of Corporations.
10.‘ That Plaintiffs are moving forward with service of process on the Defendants in this
cause of action.
11. That there is insufficient time to complete and confirm service of process on theDefendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a
Connecticut corporation, as required pursuant to the Rules of Civil Procedure and Florida Statutes.
12. That the undersigned attorney feels that service can be completed and confirmed on
the Defendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a
Connecticut corporation, and that any issues regarding process and service of process can be
resolved, and if necessary completed within an additional ninety (90) days and respectfully moves
the Court to allow such an extension of time.
WHEREFORE, Plaintiffs, CARLOS A. OSPINA and DIANE J. OSPINA, respectfully
request this Honorable Court to enter an Order allowing for an additional ninety (90) day extension
of time from the date of the Order to perfect process and service of process on the Defendants,
AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut
corporation, and to file the required documents with the Court.
I HEREBY CERTIFY that on February 19th, 2021, I electronically filed the foregoing
with the Clerk of the Courts by using the Florida Courts E-Filing Portal.
Keith T. Hill, Esq.
Florida Bar No. 0472263
Keith T. Hill, P.A.
Post Office Box 533984
Orlando, Florida 32853
(407) 898-6891
FAX (407) 896-1869
E-mail: khill @keiththillpa.com
Attorney for Plaintiffs
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Filing # 121722939 E-Filed 02/19/2021 01:52:50 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE-20-017981 CARLOS A. OSPINA and DIANE J. OSPINA, Plaintiff, vs. AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, Defendants. / PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO PERFECT PROCESS AND SERVICE OF PROCESS ON DEFENDANTS, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation Plaintiffs, CARLOS A. OSPINA and DIANE J. OSPINA, by and through their undersigned counsel, hereby file this Motion for Extension of Time to Perfect Process and Service of Process on Defendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, and in support thereof state: 1. That a lawsuit was filed in this action on October 28, 2020. 2. That a Summons issued on the Defendant, AIDA FONSECA, was forwarded with the Complaint, Request for Admissions, Request for Production, Notice of Service of Interrogatories, and Interrogatories, to Magic Process, LLC, for service on said Defendant. 3. That Jenna Guthrie of Magic Process, LLC, has advised that after four attempts to serve the Defendant, AIDA FONSECA, at 4147 Stirling Road, Apt. 502, Davie, Florida 33314, it has been determined and confirmed by her apartment complex office that she no longer resides at said address. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/19/2021 01:52:50 PM.****4. That Jay Bowen of Magic Process, LLC, advised that upon investigation, the Defendant, AIDA FONSECA, was believed to be living at 4820 SW 47" Lane, Davie, Florida 33314-4649, 5. That Jenna Guthrie of Magic Process, LLC, has advised that an attempt to serve the Defendant, AIDA FONSECA, at 4820 SW 47" Lane, Davie, Florida 33314-4649, resulted in the process server being advised that AIDA FONSECA does not reside at that address. 6. That Magic Process, LLC, is presently investigating and attempting to locate the Defendant, AIDA FONSECA. 7. That a Summons issued on the Defendant, TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, was forwarded with the Complaint, Request for Admissions, Request for Production, Notice of Service of Interrogatories, and Interrogatories, to the Chief Financial Officer, Department of Financial Services, 200 E. Gaines Street, Tallahassee, Florida 32399, for service on said Defendant. 8. That the Summons forwarded to the Chief Financial Officer, Department of Financial Services, 200 E. Gaines Street, Tallahassee, Florida 32399, was not accepted and returned non-served with an indication that The Department of Financial Services is not the agent for TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation. 9. That an Alias Summons on the Defendant, TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, has been issued and forwarded for service upon said Defendant’s registered agent, Corporation Service Company, as listed with the Division of Corporations. 10.‘ That Plaintiffs are moving forward with service of process on the Defendants in this cause of action. 11. That there is insufficient time to complete and confirm service of process on theDefendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, as required pursuant to the Rules of Civil Procedure and Florida Statutes. 12. That the undersigned attorney feels that service can be completed and confirmed on the Defendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, and that any issues regarding process and service of process can be resolved, and if necessary completed within an additional ninety (90) days and respectfully moves the Court to allow such an extension of time. WHEREFORE, Plaintiffs, CARLOS A. OSPINA and DIANE J. OSPINA, respectfully request this Honorable Court to enter an Order allowing for an additional ninety (90) day extension of time from the date of the Order to perfect process and service of process on the Defendants, AIDA FONSECA and TRAVELERS PERSONAL INSURANCE COMPANY, a Connecticut corporation, and to file the required documents with the Court. I HEREBY CERTIFY that on February 19th, 2021, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts E-Filing Portal. Keith T. Hill, Esq. Florida Bar No. 0472263 Keith T. Hill, P.A. Post Office Box 533984 Orlando, Florida 32853 (407) 898-6891 FAX (407) 896-1869 E-mail: khill @keiththillpa.com Attorney for Plaintiffs