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Filing# 143208783 E-Filed 02/03/2022 10:16:02 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.. 20-017866 CACE (14)
NANCY PARK,
Plaintiff,
VS.
BRI 1835 TCS, LLC, a Florida Limited
Liability
Company,
Defendant.
i
EXPARTE MOTION TO COMPEL DISCOVERY
COMES NOW, the Defendant, BRI 1835 TCS, LLC, by and throughundersignedcounsel,
pursuant to Florida Rules of Civil Procedure 1.380, and moves this Court for entry of an Order
pursuant to Administrative Order No. 06-09 and Rule 1.380(a)Fla. R. Civ. P., without a hearing,
compellingPlaintiff,
NANCY PARK,to comply with an outstandingdiscoveryrequest in this case
within ten (10)days and, as grounds states as follows:
1.
On May 21,2021, Defendant, BRI 1835 TCS, LLC served upon Plaintiff,NANCY PARK,
an update request for production.
2.
To date,Plaintiffhas not filed any objectionsthereto,and has not appliedfor or obtained a
protective
order,althoughthe time to respond expired.
3
To date,Plaintiffhas failed to respond to Defendant, BRI 1835 TCS, LLC' S update request
for production,althoughthey seek relevant,material information on issues raised by the pleadings,
are reasonably calculated to lead to the discovery of admissible evidence and are in complete
conformity with the applicablerules.
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/03/2022 10:16:02 AM.****
Case No: 20-017866 CACE (14)
4.
In compliance with Rule 1.380(a)(2),The Defendants certifythat the undersigned counsel notified
Plaintiff's counsel of the failure to respond, and attempted, in good faith,to secure the requested discovery,
to no avail.
WHEREFORE, Defendant, BRI 1835 TCS, LLC, requests the Court to enter an Order
compelling Plaintiff,
NANCY PARK to comply with the aforementioned discovery.
CERTIFICATE OF SERVICE
.Id
I HEREBY CERTIFY that a copy of the foregoingwas sent via electronic mail on the 3I day of
February,2022 to:
Glen B. Levine, Esquireand Danitza Gonzalez,Esquire,Law Offices of Anidjar&
Levine, P.A., Attomqsfbr the Plainti#,
300 Southeast 1771h 4Street,Fort Lauderdale, Florida 33316 at
pleadings@anl-law.com.
BY:/s/Jan Darlow Langer
JAN DARLOW BUYERS, ESQ.
Florida Bar #: 708569
com
LAW OFFICE OF MARK C. BURTON
Employees of Zurich American Insurance Company
AttorneyMDefendant
Presidential Circle,Suite 430-N
4000 Hollywood Boulevard
Hollywood, FL 33021
Telephone: (954) 989-8775
E-service: usz.slftl@zurichna.com
2
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Filing# 143208783 E-Filed 02/03/2022 10:16:02 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.. 20-017866 CACE (14) NANCY PARK, Plaintiff, VS. BRI 1835 TCS, LLC, a Florida Limited Liability Company, Defendant. i EXPARTE MOTION TO COMPEL DISCOVERY COMES NOW, the Defendant, BRI 1835 TCS, LLC, by and throughundersignedcounsel, pursuant to Florida Rules of Civil Procedure 1.380, and moves this Court for entry of an Order pursuant to Administrative Order No. 06-09 and Rule 1.380(a)Fla. R. Civ. P., without a hearing, compellingPlaintiff, NANCY PARK,to comply with an outstandingdiscoveryrequest in this case within ten (10)days and, as grounds states as follows: 1. On May 21,2021, Defendant, BRI 1835 TCS, LLC served upon Plaintiff,NANCY PARK, an update request for production. 2. To date,Plaintiffhas not filed any objectionsthereto,and has not appliedfor or obtained a protective order,althoughthe time to respond expired. 3 To date,Plaintiffhas failed to respond to Defendant, BRI 1835 TCS, LLC' S update request for production,althoughthey seek relevant,material information on issues raised by the pleadings, are reasonably calculated to lead to the discovery of admissible evidence and are in complete conformity with the applicablerules. 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/03/2022 10:16:02 AM.**** Case No: 20-017866 CACE (14) 4. In compliance with Rule 1.380(a)(2),The Defendants certifythat the undersigned counsel notified Plaintiff's counsel of the failure to respond, and attempted, in good faith,to secure the requested discovery, to no avail. WHEREFORE, Defendant, BRI 1835 TCS, LLC, requests the Court to enter an Order compelling Plaintiff, NANCY PARK to comply with the aforementioned discovery. CERTIFICATE OF SERVICE .Id I HEREBY CERTIFY that a copy of the foregoingwas sent via electronic mail on the 3I day of February,2022 to: Glen B. Levine, Esquireand Danitza Gonzalez,Esquire,Law Offices of Anidjar& Levine, P.A., Attomqsfbr the Plainti#, 300 Southeast 1771h 4Street,Fort Lauderdale, Florida 33316 at pleadings@anl-law.com. BY:/s/Jan Darlow Langer JAN DARLOW BUYERS, ESQ. Florida Bar #: 708569 com LAW OFFICE OF MARK C. BURTON Employees of Zurich American Insurance Company AttorneyMDefendant Presidential Circle,Suite 430-N 4000 Hollywood Boulevard Hollywood, FL 33021 Telephone: (954) 989-8775 E-service: usz.slftl@zurichna.com 2