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.
Preview
Filing # 126500997 E-Filed 05/10/2021 03:29:46 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
ANTONIO ALFARO and DIANA
ALFARO, CASE NO.: CACE-21-007201
Plaintiffs,
v.
TYPTAP INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFFS’ COMPLAINT AND DISCOVERY
COMES NOW Defendant, TYPTAP INSURANCE COMPANY, by and through its
undersigned counsel, and pursuant to the Florida Rule of Civil Procedure 1.090(b) hereby
seeks an Order from this Court granting Defendant an enlargement of time to respond to
Plaintiffs’ Complaint and Discovery and states as follows:
1. This case arises out of a first party property claim under a homeowners policy
issued by Defendant.
2. Plaintiffs’ Complaint was served on Defendant on April 19, 2021, making the
response due on Monday, May 10, 2021.
3. The undersigned was recently retained in this matter and requires additional
time to review the file and confer with the client in order to properly respond to
the lawsuit.
4. Plaintiffs will not be prejudiced by the granting of this Motion.
5. This Motion is being made in good faith and not for the purposes of delay.
6. Defendant respectfully requests this Court grant Defendant additional time
within which to respond to Plaintiffs’ Complaint and Discovery.
COLE, SCOTT & KISSANE, P.A.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/10/2021 03:29:45 PM.****WHEREFORE, Defendant, TYPTAP INSURANCE COMPANY, respectfully re-
quests this Honorable Court grant Defendant’s Motion and enter an Order allowing De-
fendant an additional 30 days from the date of this Court’s order to respond to Plaintiffs’
Complaint and an additional 20 days from the date the response to Plaintiffs’ Complaint
is due to respond to Plaintiffs’ discovery.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 10th day of May, 2021, a true and correct copy of
the foregoing was filed with the Clerk of Broward County by using the Florida Courts e-
Filing Portal, which will send an automatic e-mail message to the following parties regis-
tered with the e-Filing Portal system: Maximo A. Santiago, Esq,, Your Insurance Attorney,
PLLC, yia3@yourinsuranceattorney.com;eservice@yourinsuranceattorney.com, 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 TYPTAP INSURANCE
COMPANY
Esperante Building
222 Lakeview Avenue, Suite 120
West Palm Beach, Florida 33401
Telephone (561) 383-9252
Facsimile (561) 683-8977
Primary e-mail: mimi.mcandrews@csklegal.com
Secondary e-mail: jacqueline. meyer@csklegal.com
Alternate e-mail: stacey.nafis@csklegal.com
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.
ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX
Document Filed Date
May 10, 2021
Case Filing Date
April 09, 2021
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Filing # 126500997 E-Filed 05/10/2021 03:29:46 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ANTONIO ALFARO and DIANA ALFARO, CASE NO.: CACE-21-007201 Plaintiffs, v. TYPTAP INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT AND DISCOVERY COMES NOW Defendant, TYPTAP INSURANCE COMPANY, by and through its undersigned counsel, and pursuant to the Florida Rule of Civil Procedure 1.090(b) hereby seeks an Order from this Court granting Defendant an enlargement of time to respond to Plaintiffs’ Complaint and Discovery and states as follows: 1. This case arises out of a first party property claim under a homeowners policy issued by Defendant. 2. Plaintiffs’ Complaint was served on Defendant on April 19, 2021, making the response due on Monday, May 10, 2021. 3. The undersigned was recently retained in this matter and requires additional time to review the file and confer with the client in order to properly respond to the lawsuit. 4. Plaintiffs will not be prejudiced by the granting of this Motion. 5. This Motion is being made in good faith and not for the purposes of delay. 6. Defendant respectfully requests this Court grant Defendant additional time within which to respond to Plaintiffs’ Complaint and Discovery. COLE, SCOTT & KISSANE, P.A. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/10/2021 03:29:45 PM.****WHEREFORE, Defendant, TYPTAP INSURANCE COMPANY, respectfully re- quests this Honorable Court grant Defendant’s Motion and enter an Order allowing De- fendant an additional 30 days from the date of this Court’s order to respond to Plaintiffs’ Complaint and an additional 20 days from the date the response to Plaintiffs’ Complaint is due to respond to Plaintiffs’ discovery. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 10th day of May, 2021, a true and correct copy of the foregoing was filed with the Clerk of Broward County by using the Florida Courts e- Filing Portal, which will send an automatic e-mail message to the following parties regis- tered with the e-Filing Portal system: Maximo A. Santiago, Esq,, Your Insurance Attorney, PLLC, yia3@yourinsuranceattorney.com;eservice@yourinsuranceattorney.com, 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 TYPTAP INSURANCE COMPANY Esperante Building 222 Lakeview Avenue, Suite 120 West Palm Beach, Florida 33401 Telephone (561) 383-9252 Facsimile (561) 683-8977 Primary e-mail: mimi.mcandrews@csklegal.com Secondary e-mail: jacqueline. meyer@csklegal.com Alternate e-mail: stacey.nafis@csklegal.com 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. ESPERANTE BUILDING - 222 LAKEVIEW AVENUE, SUITE 120 - WEST PALM BEACH, FLORIDA 33401 (561) 383-9200 - (561) 683-8977 FAX