On April 16, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Pickering, Carol,
Pickering, Jeffrey,
and
United Property And Casualty Insurance Company,
for 3
in the District Court of Broward County.
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Filing # 130322048 E-Filed 07/09/2021 09:10:45 AM
IN THE CIRCUIT COURT OF THE 17th
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CIRCUIT COURT DIVISION
CASE NO: CACE-21-007806
CAROL PICKERING AND JEFFREY
PICKERING,
Plaintiffs,
V
UNITED PROPERTY &
CASUALTY INSURANCE
COMPANY,
Defendant.
i
PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO
DEFENDANT'S DISCOVERY REOUESTS
Plaintiffs, CAROL PICKERING AND JEFFREY PICKERING, move this Court for an Order
extending the time to respond to Defendant's, UNITED PROPERTY & CASUALTY
INSURANCE COMPANY, DiscoveryRequests. In support of this Motion the Plaintiffs state as
follows:
1
On or about June 9, 2021, Plaintiffs were served with Defendant's
DiscoveryRequests.
2.
Plaintiffs seek additional time in which to adequatelyrespond toDefendant's
DiscoveryRequests by 30 days.
3.
Plaintiffs are not seeking to extend any other deadlines.
4.
An extension oftime for the requested deadline will be sufficient to adequatelyfile
a response to Defendant's DiscoveryRequests.
5.
Furthermore, an extension ofthe deadline will not prejudice eitherparty.
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 07/09/2021 09:10:45 AM.****
WHEREFORE, Plaintiffs,
CAROL
PICKERING
AND
JEFFREY
PICKERING,
respectfully request that this Court enter an Order granting this Motion to Extend the time
in which response to the Defendant's DiscoveryRequests are due, and for any further relief
this Court deemsjust and proper.
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Florida
E-Portal to all parties on this 9z.th day of July 2021.
Your InsuranceAttorney,PLLC.
2601 South Bayshore Drive 18th Floor
Coconut Grove, FL 33133
Phone No.: 1-888-570-5677
Fax: 1-888-745-5677
Secondary Email:
By-. /sl Maximo A. Santiago
MAximo A. Santiago, Esq.
Florida Bar No. 669733
Ariana Rubio Di Natale, Esq.
Florida Bar No. 1025882
Document Filed Date
July 09, 2021
Case Filing Date
April 16, 2021
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Filing # 130322048 E-Filed 07/09/2021 09:10:45 AM IN THE CIRCUIT COURT OF THE 17th JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CIRCUIT COURT DIVISION CASE NO: CACE-21-007806 CAROL PICKERING AND JEFFREY PICKERING, Plaintiffs, V UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO DEFENDANT'S DISCOVERY REOUESTS Plaintiffs, CAROL PICKERING AND JEFFREY PICKERING, move this Court for an Order extending the time to respond to Defendant's, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, DiscoveryRequests. In support of this Motion the Plaintiffs state as follows: 1 On or about June 9, 2021, Plaintiffs were served with Defendant's DiscoveryRequests. 2. Plaintiffs seek additional time in which to adequatelyrespond toDefendant's DiscoveryRequests by 30 days. 3. Plaintiffs are not seeking to extend any other deadlines. 4. An extension oftime for the requested deadline will be sufficient to adequatelyfile a response to Defendant's DiscoveryRequests. 5. Furthermore, an extension ofthe deadline will not prejudice eitherparty. *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 07/09/2021 09:10:45 AM.**** WHEREFORE, Plaintiffs, CAROL PICKERING AND JEFFREY PICKERING, respectfully request that this Court enter an Order granting this Motion to Extend the time in which response to the Defendant's DiscoveryRequests are due, and for any further relief this Court deemsjust and proper. CERTIFICATEOF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Florida E-Portal to all parties on this 9z.th day of July 2021. Your InsuranceAttorney,PLLC. 2601 South Bayshore Drive 18th Floor Coconut Grove, FL 33133 Phone No.: 1-888-570-5677 Fax: 1-888-745-5677 Secondary Email: By-. /sl Maximo A. Santiago MAximo A. Santiago, Esq. Florida Bar No. 669733 Ariana Rubio Di Natale, Esq. Florida Bar No. 1025882