On April 09, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Alfaro, Antonio,
Arevalo, Diana,
and
Typtap Insurance Company,
for 3
in the District Court of Broward County.
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Filing # 128991737 E-Filed 06/17/2021 04:27:51 PM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
ANTONIO ALFARO AND DIANA
CASE NO.: CACE21007201
AREVALO
Plaintiffs,
V
TYPTAP INSURANCE COMPANY,
Defendant.
DEFENDANT'S MOTION FOR PROTECTIVE ORDER
AND MOTION TO STAY DISCOVERY
COMES NOW, the Defendant, TYPTAP INSURANCE COMPANY, (hereinafter
"TYPTAP") by and through its undersigned counsel, files its Motion for Protective Order
and Motion to Stay Discovery and would state as follows:
1. This case arises out of a first party property claim related to damage reportedly
from a plumbing loss.
2. The Plaintiffs have filed a Petition for Declaratory Relief as Count Il to their Com-
plaint. The Defendant has pending a Motion to Dismiss Count Il of the Plaintiffs'
Complaint, filed contemporaneouslyherewith.
3. Accordingly, Defendant moves to stay the litigation of this case, pending this Hon-
orable Court's ruling on Defendant'sMotion to Dismiss Count Il of Plaintiffs'Com-
plaint.
WHEREFORE, the Defendant, TYPTAP INSURANCE COMPANY, respectfully re-
guests this Court enter an Order granting Defendant's Motion for Protective Order and
COLE, SCOTT & KISSANE, P.A.
ESPERANTEBUILDING - 222 LAKEVIEWAVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA33401 (561) 383-
9200 - (561) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/17/2021 04:27:51 PM.****
CASE NO.: CACE21007201
Motion to Stay discovery in this case pending the resolution of Defendant's Motion to
Dismiss Count Il of Plaintiffs' Complaint and grant any other relief deemed just and proper
by this Honorable Court.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 17th day of June, 2021, a true and correct copy
of the foregoing was filed with the Clerk of County by using the Florida Courts e-Filing
Portal, which will send an automatic e-mail message to the following parties registered
with the e-Filing Portal system: Maximo A. Santiago, Esq,, Your Insurance Attorney,
PLLC,
2601
South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570-5677/(888) 745-
5677 (F), Attorney for Plaintiffs, Diana Arevalo and Antonio Alfaro.
COLE, SCOTT & KISSANE, P.A.
Counsel for Defendant
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9252
Facsimile (561) 683-8977
Primary e-mail:
Secondarye-mail:
Alternate e-mail:
By: s/ Jacqueline P. Meyer
MIMI K. MCANDREWS
Florida Bar No.- 991368
JACQUELINE P. MEYER
Florida Bar No.: 1010785
2
COLE, SCOTT & KISSANE, P.A.
ESPERANTEBUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA33401 (561) 383-
9200 - (561) 683-8977 FAX
Document Filed Date
June 17, 2021
Case Filing Date
April 09, 2021
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Filing # 128991737 E-Filed 06/17/2021 04:27:51 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ANTONIO ALFARO AND DIANA CASE NO.: CACE21007201 AREVALO Plaintiffs, V TYPTAP INSURANCE COMPANY, Defendant. DEFENDANT'S MOTION FOR PROTECTIVE ORDER AND MOTION TO STAY DISCOVERY COMES NOW, the Defendant, TYPTAP INSURANCE COMPANY, (hereinafter "TYPTAP") by and through its undersigned counsel, files its Motion for Protective Order and Motion to Stay Discovery and would state as follows: 1. This case arises out of a first party property claim related to damage reportedly from a plumbing loss. 2. The Plaintiffs have filed a Petition for Declaratory Relief as Count Il to their Com- plaint. The Defendant has pending a Motion to Dismiss Count Il of the Plaintiffs' Complaint, filed contemporaneouslyherewith. 3. Accordingly, Defendant moves to stay the litigation of this case, pending this Hon- orable Court's ruling on Defendant'sMotion to Dismiss Count Il of Plaintiffs'Com- plaint. WHEREFORE, the Defendant, TYPTAP INSURANCE COMPANY, respectfully re- guests this Court enter an Order granting Defendant's Motion for Protective Order and COLE, SCOTT & KISSANE, P.A. ESPERANTEBUILDING - 222 LAKEVIEWAVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA33401 (561) 383- 9200 - (561) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/17/2021 04:27:51 PM.**** CASE NO.: CACE21007201 Motion to Stay discovery in this case pending the resolution of Defendant's Motion to Dismiss Count Il of Plaintiffs' Complaint and grant any other relief deemed just and proper by this Honorable Court. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 17th day of June, 2021, a true and correct copy of the foregoing was filed with the Clerk of County by using the Florida Courts e-Filing Portal, which will send an automatic e-mail message to the following parties registered with the e-Filing Portal system: Maximo A. Santiago, Esq,, Your Insurance Attorney, PLLC, 2601 South Bayshore Drive, 18th Floor, Coconut Grove, FL 33133, (888) 570-5677/(888) 745- 5677 (F), Attorney for Plaintiffs, Diana Arevalo and Antonio Alfaro. COLE, SCOTT & KISSANE, P.A. Counsel for Defendant Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9252 Facsimile (561) 683-8977 Primary e-mail: Secondarye-mail: Alternate e-mail: By: s/ Jacqueline P. Meyer MIMI K. MCANDREWS Florida Bar No.- 991368 JACQUELINE P. MEYER Florida Bar No.: 1010785 2 COLE, SCOTT & KISSANE, P.A. ESPERANTEBUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA33401 (561) 383- 9200 - (561) 683-8977 FAX