On April 15, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Ben-Ishay, Amir,
Ben-Ishay, Nechama,
and
Typtap Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing# 138230271 E-Filed 1 1/09/2021 06:04:33 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
NECHAMA & AMIR BEN-ISHAY,
Plaintiffs,
VS.
Case No: CACE-21-007642
TYPTAP INSURANCE COMPANY,
Defendant.
i
PLAINTIFF'S MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANT'S DISCOVERY REQUESTS
Plaintiff,
by and through its undersigned counsel and pursuant to Rule 1.510 of the
Florida Rules of Civil Procedure, hereby files this Motion for Extension of Time to Respond to
Defendant's Discovery Requests, and in support thereof, states as follows:
1.
Defendant served Plaintiff with Defendant's Discovery Requests.
2.
The responses to Defendant's Discovery Requests are due.
3.
Plaintiff's Counsel is seeking additional time to respond to Defendant's Discovery
Requests.
4.
The Defendant will not be prejudicedby the grantingof this Motion.
5.
This Motion is being made in good faith and not for the purpose of delay.
WHEREFORE, Plaintiffs respectfullyrequest that this Court enter an Order grantingthis
Motion and grantingany further relief this Court deems justand proper under the circumstances.
DATED this November 9,2021.
BY:
/s/ Alena Lulchak
ALENA LULCHAK, ESQ.
RespectfullySubmitted,
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2021 06:04:33 PM.****
/s/ Alena Lulchak
ALENA LULCHAK, ESQ.
Florida Bar No. 1011375
BRETT L. SCHLACTER, ESQ.
Florida Bar No. 98112
SCHLACTER LAW
1108 Kane Concourse, Suite 305
Bay Harbor Islands,Florida 33154
(305) 999 - 1111 (Telephone)
(305)440 - 1354 (Facsimile)
E-mail: alena@schlacterlaw.com
E-mail: sheryl@schlacterlaw.com
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on
Defendant's Attorney via E-File list-serve on November 9,2021.
BY:
/s/ Brett L. Schlacter
BRETT L. SCHLACTER, ESQ.
2
Document Filed Date
November 09, 2021
Case Filing Date
April 15, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing# 138230271 E-Filed 1 1/09/2021 06:04:33 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NECHAMA & AMIR BEN-ISHAY, Plaintiffs, VS. Case No: CACE-21-007642 TYPTAP INSURANCE COMPANY, Defendant. i PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT'S DISCOVERY REQUESTS Plaintiff, by and through its undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Extension of Time to Respond to Defendant's Discovery Requests, and in support thereof, states as follows: 1. Defendant served Plaintiff with Defendant's Discovery Requests. 2. The responses to Defendant's Discovery Requests are due. 3. Plaintiff's Counsel is seeking additional time to respond to Defendant's Discovery Requests. 4. The Defendant will not be prejudicedby the grantingof this Motion. 5. This Motion is being made in good faith and not for the purpose of delay. WHEREFORE, Plaintiffs respectfullyrequest that this Court enter an Order grantingthis Motion and grantingany further relief this Court deems justand proper under the circumstances. DATED this November 9,2021. BY: /s/ Alena Lulchak ALENA LULCHAK, ESQ. RespectfullySubmitted, *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/09/2021 06:04:33 PM.**** /s/ Alena Lulchak ALENA LULCHAK, ESQ. Florida Bar No. 1011375 BRETT L. SCHLACTER, ESQ. Florida Bar No. 98112 SCHLACTER LAW 1108 Kane Concourse, Suite 305 Bay Harbor Islands,Florida 33154 (305) 999 - 1111 (Telephone) (305)440 - 1354 (Facsimile) E-mail: alena@schlacterlaw.com E-mail: sheryl@schlacterlaw.com I HEREBY CERTIFY that a true and correct copy of the foregoing was served on Defendant's Attorney via E-File list-serve on November 9,2021. BY: /s/ Brett L. Schlacter BRETT L. SCHLACTER, ESQ. 2