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Filing # 130212528 E-Filed 07/07/2021 04:49:25 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
CAMALA LEWIS DIXON,
Plaintiff,
V
CASE NO.: CACE-20-017636
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFF'S 1MOTION TO COMPEL DEFENDANT'S DISCOVERY RESPONSES
COMES NOW, the Plaintiff, Camala Lewis Dixon, by and through the undersigned
counsel and in accordance with the applicable Florida Rules of Civil Procedure hereby requests
this Court to enter an Order compelling Defendant, Universal Property & Casualty Insurance
Company, to respond to the Plaintiffs' Interrogatories, Request for Production, Request for
Admissions, and in supportthereofstate as follows:
1.
The subject lawsuit stems from a claim for homeowner's insurance benefits.
2.
On October 22,2020, Plaintifffiled her First Set of Interrogatories,Request for
Production, Request for Admissions, along with its Complaint, which was subsequentlyserved on
Defendant on November 6,2020.
3
On November 30,2020, Defendant filed Motion for Extension of Time to Respond
to Plaintiff's Complaint as well as the DiscoveryRequests. See attached hereto as Exhibit "A."
4.
On December 15, 2020, the parties entered into an Agreed Order on Defendant's
Motion for Extension of Time. See attached hereto as Exhibit "B."
5.
The Defendant did not comply with the Court Order entered on December 15,2020
and filed its second Motion for Extension of time on January 7,2021, requesting more time to file
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/07/2021 04:43:28 PM.****
its response to the Complaint in this instant action as well as serve its responses to the Plaintiff's
initial discovery. See attached hereto as Exhibit "C."
6.
On March 29,2021, counsel for the Plaintiffadvisedcounsel for Defendantthat the
Defendant's discovery responses were still outstanding, and counsel for Plaintiff offered an
additional 14 days for a"third and final extension." See correspondence attachedhereto as Exhibit
U.
7.
On June 4, 2021, counsel for the Plaintiff again communicated electronicallywith
the counsel for Defendant and advised that the there are several pending motions and outstanding
discovery due. See attached hereto as Exhibit "E...
8
Defendant responded twenty-five (25) days later on June 29, 2021 and provided a
proposed Agreed Order with dates into August, well over 9 months after the Discovery Requests
were served. See attached hereto as CompositeExhibit "F ..
9.
To date, Defendant has failed to provide responses to Defendant's Discovery
Requests.
WHEREFORE, the Plaintiff, Camala Lewis Dixon, respectfully requests that this
Honorable Court enter an Order requiringthe Defendantto provide full and completeresponsesto
Plaintiffs First Request for Admissions, First Request for Production and First Set of
Interrogatories,and for any other relief it may deemjust and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnishedto: Ashley Joseph, Esq., Attorney for Defendant,Universal Property & Casualty
Insurance
Company,
using
the
Florida
Courts
E-Filing
Portal,
to:
and
on this 7 th day of July, 2021.
By-. U Adam Shamir
ADAM SHAMIR, ESQ.
Florida Bar No: 99647
WEISSER ELAZAR & KANTOR, PLLC
Attorney for Plaintiff
800 East Broward Boulevard, Suite 510
Fort Lauderdale,Florida 33301
T: (954) 486-2623
F: (954) 572-8695
Email: ASH@WEKLaw.com
KL@WEKLaw.com
RP@WEKLaw.com
Filing # 117325813 E-Filed 11/30/2020 08:02:59 AM
EXHIBIT "A"
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CAN[ALA LEWIS DIXON,
CASE NO.: CACE-20-017636
Plaintiff.
VS.
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
I
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT
AND DISCOVERY REOUESTS SERVED WITH THE SUMMONS AND COMPLAINT
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
('1Tniversal"),by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plintiff's Complaint and Discovery Requests served with the Summons and
Complaint, and states as follows:
1.
This matter arises out ofa claim asserted by CAMALA LEWIS DIXON ("Plaintiff')
against Universal for damages arising out of and resulting from alleged damage occurring on
September 10,2017.
2.
The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery
Requests, however, additional time is necessary to respond and as such, Universal would
respectfully requests an additional thirty (30) days from the date of this Motion to review the file,
discuss early resolution, and ifnecessary, file a responsivepleading to Plaintiffs Complaint and
an additional twenty (20) days thereafterto respondto Plaintiff's Discovery Requests.
3.
This Motion is not being filed for the purposes of delay and will not prejudice any
party.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1 1/30/2020 08:02:58 AM.****
CACE-20-017636
Page 2 of2
WHEREFORE,Universal Propertyand CasualtyInsuranceCompany respectfully requests
this Court to enter an Order granting Defendant an additional thirty (30) days to respond to
Plaintiff's Complaint and an additional twenty (20) days thereafter to respond to Plaintiffs
DiscoveryRequests.
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Kevin Weisser, Esq. (kw@weklaw.com)on November 30,2020.
Attorneyfor Defendant
Universal Property & Casualty Insurance Company
P.O. Box 9388
Fort Lauderdale,Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594WudgesMD,)
Facsimile: (954) 958-1262
By: /s/ Alina Maria Alvarez
Alina Maria Alvarez, Esq.
Florida Bar No. 127087
For Service of Court Documents only:
Primary:
Secondary:
Tertiary:
For Scheduling Matters:
*Please do not send any inquiries or schedulingmattersto
or
Filing # 118225267 E-Filed 12/15/2020 12:17:03 PM
EXHIBIT "B"
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE20017636
DIVISION 02
JUDGE John Bowman
Camala Lewis Dixon
Plaintiffts)/ Petitioner(s)
V.
Universal Property & Casualty Insurance Company
Defendant(s)/ Respondent(s)
I
AGREED ORDER ON DEFENDANT'S REQUEST FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY
THIS MATTER, having come before the Court on Defendant's Request for Extension of Time to
Respond to Plaintiffs Complaint and Discovery,through the agreement of the parties, and the Court having
been otherwise advised in the Premises, it is hereby:
ORDERED AND ADJUDGED that Defendant's Request for Extension of time is hereby GRANTED.
1.
Defendant shall file a response to Plaintiffs Complainton or before January 7, 2021.
2.
Defendant shall file a response to Plaintiffs Discovery Requests on or before Janaury 18,2021.
3.
Plaintiffs counsel has read the Agreed Order and has no objection to the entry of same.
DONE and ORDERED in Chambers, at Broward County, Florida on 12-15-2020.
-VPGZG,4A-S-1 5-2020 84=44 AAC
CACE2001763612-15-2020 8:44 AM
Hon. John Bowman
CIRCUIT JUDGE
Electronically Signed by John Bowman
Copies Furnished To:
Alina Maria Alvarez, E-mail :
Alina Maria Alvarez
E-mail :
,
Alina Maria Alvarez
E-mail :
,
Ashley Joseph, E-mail :
Ashley Joseph, E-mail :
Ashley Joseph, E-mail :
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2020 12:17:02 PM.****
CaseNo: CACE20017636
Page 2 of 2
Kevin Weisser, E-mail : ab@weklaw.com
Kevin Weisser, E-mail : pb@weklaw.com
Kevin Weisser, E-mail : kw@weklaw.com
Sapir Elazar, E-mail : JM@WEKLaw.com
Sapir Elazar, E-mail : AB@WEKLaw.com
Sapir Elazar, E-mail : SE@WEKLaw.com
Filing # 119195918 E-Filed 01/07/2021 08:36:51 AM
EXHIBIT "C"
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CAN[ALA LEWIS DIXON,
CASE NO.: CACE-20-017636
Plaintiff.
VS.
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
I
SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF'S COMPLAINT AND DISCOVERY REOUESTS SERVED
WITH THE SUMMONS AND COMPLAINT
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
('1Tniversal"), by and through the undersigned counsel, hereby files its Second Motion for
Extension of Time to Respond to Plaintiff's Complaint and Discovery Requests served with the
Summons and Complaint, and states as follows:
1.
This matter arises out ofa claim asserted by CAMALA LEWIS DIXON ("Plaintiff')
against Universal for damages arising out of and resulting from alleged damage occurring on
September 10, 2017.
2.
The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery
Requests, however, additional time is necessary to respond and as such, Universal would
respectfully requests an additional thirty (30) days from the date of this Motion to review the file,
discuss early resolution, and ifnecessary, file a responsivepleading to Plaintiffs Complaint and
an additional twenty (20) days thereafterto respond to Plaintiff's Discovery Requests.
3.
This Motion is not being filed for the purposes of delay and will not prejudice any
party.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/07/2021 08:36:51 AM.****
CACE-20-017636
Page 2 of2
WHEREFORE,Universal Propertyand CasualtyInsuranceCompany respectfully requests
this Court to enter an Order granting Defendant an additional thirty (30) days to respond to
Plaintiff's Complaint and an additional twenty (20) days thereafter to respond to Plaintiff's
DiscoveryRequests.
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Kevin Weisser, Esq. *w@weklaw.com;pb@weklaw.com) on January 7,2021.
Attorneyfor Defendant
Universal Property & Casualty Insurance Company
P.O. Box 9388
Fort Lauderdale,Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594WudgesMD,)
Facsimile: (954) 958-1262
By: /s/ Alina Maria Alvarez
Alina Maria Alvarez, Esq.
Florida Bar No. 127087
For Service of Court Documents only:
Primary:
Secondary:
Tertiary:
For Scheduling Matters:
*Please do not send any inquiries or schedulingmattersto
or
EXHIBIT "D"
Adam Shamir
From:
Adam Shamir
Sent:
Monday, March 29, 2021 11:51 AM
To:
mI0225
Subject:
LEWIS DIXON, CAMALA VS UNIVERSAL PROPERTY & CASUALTY
Attachments:
Motion For Extension Of Time.pdf
Hi Alina,
I'll be taking over this matter going forward. I see that you filed a second MET on 1/7/21 seeking 30 days to respond to
the complaint and 20 days for discovery. I'll agree to a third and final extension of 14 days from today. Please send a
proposed order on same.
Lastly, there are 3 open suits for this insured (FLZO-0117771,FLZO-0117770, FLZO-0117768-E317) so let me know if your
client is interested in a global settlement.
Regards,
Adam
Adam Shamir, Esq.
068--81-r,MW
%.
800 East Broward Blvd., Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
- .weklaw.com
1
EXHIBIT "E"
From:
Kory Luciano
To:
CC:
Adam Shamir
Subject:
Overdue Responses - CAMALA LEWIS DIXON V UNIVERSAL- CASE NUMBER CACE 20 017636 - CLAIM NUMBER
FL20 0117768 E317
Date:
Friday, June 4, 2021 5:04:00PM
Attachments:
image001.png
Good Afternoon,
I have been charged with review of the court filing relating to the above referenced matter.
At this time, the following Motions are pending:
Defendant's Second Motion for Extension of Time to Respond to Plaintiffs Complaint and Initial
Discovery
And
Defendant's Motion for Protective Order, as it relates to Plaintiffs Notice of Taking Deposition of
Defendant''s Corporate Representative.
Attorney Shamir is amenable to entering into a second Agreed Order allowing the Defendant ten
(10) days to Respond to the Complaint and responses to Discovery, if your office provides the
undersigned with a proposed Agreed Order by 4 pm on Wednesday, June 9, 2021.
As far as the pending Motion for Protective Order, I have no issue mutuallycoordinating the
deposition. Please have your scheduling assistant provide the undersigned with dates and times to
depose the field/independent adjusterand Corporate Representative by 4 pm, Wednesday June 9,
2021.
Thank you and have a great day.
Kory Luciano
Paralegal to Adam Shamir, Esquire
Weisser Elazar & Kantor, PLLC
800 East Broward Blvd., Suite 510
Fort Lauderdale, Florida 33301
T: (954) 486-2623
F: (954) 572-8695
www.weklaw.com
CONFIDENTIALITY NOTICE:"Thismessage and any attached informationis from Weisser Elazar & Kantor PLLC, and may contain
confidentialand/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed.
Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is
unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended
recipient(s)shall not be construed as a waiverof any privilegeor confidence. If you receivethis transmission in error, please contact the
sender by return e-mailand deletethe material."
COMPOSITE EXHIBIT "F"
From:
Melinda Lawson
To:
Adam Shamir; Korv Luciano
CC:
Alina Maria Alvarez; Fallen Gardner, F.R.P.; Melinda Lawson
Subject:
Regarding: CAMALA LEWIS DIXON V. UPCIC (Irma) - Claim No: FL20-0117768-E317 / PAO Complaintand
Discovery
Date:
Tuesday, June 29, 2021 9:10:54AM
Attachments:
image662000.png
DF"s Revised Proposed Order on DF"s Second MEXT.pdf
Good Morning,
Pursuant to the Defendant's Second Motion for Extension of Time
previously filed, attached please find a proposed Agreed Order for your
review. I included language regarding Plaintiff's outstanding discovery
responses.
Please advise if OK to submit to the Court.
Please note: There may be a delay in response due to vast amount of e-
mails received.
Thank you,
Melinda Lawson
Legal Assistant
(W): (954) 958-1200 ext:6716
(Direct): (954) 372-1765
UNIVERSAL
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Join us and GO GREEN! Go paperless with Universal.
ConfidentialityNotice: This e-mail message,including
any attachments, is for the sole use of the intended recipient(s)and may
contain confidentialand privileged information. Any unauthorized review, use,
disclosureor distribution is prohibited.If you are not the intended recipient
and received this in error, please contact the sender by reply e-mail. You are
hereby notified that the copying, use or distribution of any information or
materialstransmittedin or with this message is strictly prohibited.
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CAMALA LEWIS DIXON,
CASE NO.: CACE-20-017636-13
Plaintiff,
VS.
UNIVERSALPROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
AGREED ORDER ON DEFENDANT'S SECOND 1MOTION FOR EXTENSION OF
TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY
THIS MATTER, having come before the Court on Defendant's Second Motion for
Extension of Time to Respondto Plaintiffs Complaint and Discovery, through the agreement of
the parties, and the Court having been otherwise advised in the Premises, it is hereby:
ORDERED AND ADJUDGED that Defendant's Second Motion for Extension oftime is
hereby GRANTED.
1.
Defendant shall file a response to Plaintiff's Complaint on or before July 16, 2021.
2.
Defendant shall file a response to Plaintiffs Discovery Requests on or before August 6,
2021.
3.
Plaintiff shall file a response to Defendant:'s Discovery Requests on or before August 13,
2021.
DONE AND ORDERED in Chambers in Broward County, Fort Lauderdale, Florida on
this
of
,2021.
,
CIRCUIT COURT JUDGE
CACE-20-017636-13
Page 2 of 2
Copies Furnished to:
Alina Maria Alvarez, Esq., Attorney for Defendant,
and
Adam Shamir, Esq., Attorney for Plaintiff, ash@weklaw.com;kl@weklaw.com
Preview
Filing # 130212528 E-Filed 07/07/2021 04:49:25 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CAMALA LEWIS DIXON, Plaintiff, V CASE NO.: CACE-20-017636 UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFF'S 1MOTION TO COMPEL DEFENDANT'S DISCOVERY RESPONSES COMES NOW, the Plaintiff, Camala Lewis Dixon, by and through the undersigned counsel and in accordance with the applicable Florida Rules of Civil Procedure hereby requests this Court to enter an Order compelling Defendant, Universal Property & Casualty Insurance Company, to respond to the Plaintiffs' Interrogatories, Request for Production, Request for Admissions, and in supportthereofstate as follows: 1. The subject lawsuit stems from a claim for homeowner's insurance benefits. 2. On October 22,2020, Plaintifffiled her First Set of Interrogatories,Request for Production, Request for Admissions, along with its Complaint, which was subsequentlyserved on Defendant on November 6,2020. 3 On November 30,2020, Defendant filed Motion for Extension of Time to Respond to Plaintiff's Complaint as well as the DiscoveryRequests. See attached hereto as Exhibit "A." 4. On December 15, 2020, the parties entered into an Agreed Order on Defendant's Motion for Extension of Time. See attached hereto as Exhibit "B." 5. The Defendant did not comply with the Court Order entered on December 15,2020 and filed its second Motion for Extension of time on January 7,2021, requesting more time to file *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/07/2021 04:43:28 PM.**** its response to the Complaint in this instant action as well as serve its responses to the Plaintiff's initial discovery. See attached hereto as Exhibit "C." 6. On March 29,2021, counsel for the Plaintiffadvisedcounsel for Defendantthat the Defendant's discovery responses were still outstanding, and counsel for Plaintiff offered an additional 14 days for a"third and final extension." See correspondence attachedhereto as Exhibit U. 7. On June 4, 2021, counsel for the Plaintiff again communicated electronicallywith the counsel for Defendant and advised that the there are several pending motions and outstanding discovery due. See attached hereto as Exhibit "E... 8 Defendant responded twenty-five (25) days later on June 29, 2021 and provided a proposed Agreed Order with dates into August, well over 9 months after the Discovery Requests were served. See attached hereto as CompositeExhibit "F .. 9. To date, Defendant has failed to provide responses to Defendant's Discovery Requests. WHEREFORE, the Plaintiff, Camala Lewis Dixon, respectfully requests that this Honorable Court enter an Order requiringthe Defendantto provide full and completeresponsesto Plaintiffs First Request for Admissions, First Request for Production and First Set of Interrogatories,and for any other relief it may deemjust and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnishedto: Ashley Joseph, Esq., Attorney for Defendant,Universal Property & Casualty Insurance Company, using the Florida Courts E-Filing Portal, to: and on this 7 th day of July, 2021. By-. U Adam Shamir ADAM SHAMIR, ESQ. Florida Bar No: 99647 WEISSER ELAZAR & KANTOR, PLLC Attorney for Plaintiff 800 East Broward Boulevard, Suite 510 Fort Lauderdale,Florida 33301 T: (954) 486-2623 F: (954) 572-8695 Email: ASH@WEKLaw.com KL@WEKLaw.com RP@WEKLaw.com Filing # 117325813 E-Filed 11/30/2020 08:02:59 AM EXHIBIT "A" IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CAN[ALA LEWIS DIXON, CASE NO.: CACE-20-017636 Plaintiff. VS. UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. I MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY REOUESTS SERVED WITH THE SUMMONS AND COMPLAINT Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ('1Tniversal"),by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plintiff's Complaint and Discovery Requests served with the Summons and Complaint, and states as follows: 1. This matter arises out ofa claim asserted by CAMALA LEWIS DIXON ("Plaintiff') against Universal for damages arising out of and resulting from alleged damage occurring on September 10,2017. 2. The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery Requests, however, additional time is necessary to respond and as such, Universal would respectfully requests an additional thirty (30) days from the date of this Motion to review the file, discuss early resolution, and ifnecessary, file a responsivepleading to Plaintiffs Complaint and an additional twenty (20) days thereafterto respondto Plaintiff's Discovery Requests. 3. This Motion is not being filed for the purposes of delay and will not prejudice any party. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1 1/30/2020 08:02:58 AM.**** CACE-20-017636 Page 2 of2 WHEREFORE,Universal Propertyand CasualtyInsuranceCompany respectfully requests this Court to enter an Order granting Defendant an additional thirty (30) days to respond to Plaintiff's Complaint and an additional twenty (20) days thereafter to respond to Plaintiffs DiscoveryRequests. CERTIFICATEOF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Kevin Weisser, Esq. (kw@weklaw.com)on November 30,2020. Attorneyfor Defendant Universal Property & Casualty Insurance Company P.O. Box 9388 Fort Lauderdale,Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594WudgesMD,) Facsimile: (954) 958-1262 By: /s/ Alina Maria Alvarez Alina Maria Alvarez, Esq. Florida Bar No. 127087 For Service of Court Documents only: Primary: Secondary: Tertiary: For Scheduling Matters: *Please do not send any inquiries or schedulingmattersto or Filing # 118225267 E-Filed 12/15/2020 12:17:03 PM EXHIBIT "B" IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE20017636 DIVISION 02 JUDGE John Bowman Camala Lewis Dixon Plaintiffts)/ Petitioner(s) V. Universal Property & Casualty Insurance Company Defendant(s)/ Respondent(s) I AGREED ORDER ON DEFENDANT'S REQUEST FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY THIS MATTER, having come before the Court on Defendant's Request for Extension of Time to Respond to Plaintiffs Complaint and Discovery,through the agreement of the parties, and the Court having been otherwise advised in the Premises, it is hereby: ORDERED AND ADJUDGED that Defendant's Request for Extension of time is hereby GRANTED. 1. Defendant shall file a response to Plaintiffs Complainton or before January 7, 2021. 2. Defendant shall file a response to Plaintiffs Discovery Requests on or before Janaury 18,2021. 3. Plaintiffs counsel has read the Agreed Order and has no objection to the entry of same. DONE and ORDERED in Chambers, at Broward County, Florida on 12-15-2020. -VPGZG,4A-S-1 5-2020 84=44 AAC CACE2001763612-15-2020 8:44 AM Hon. John Bowman CIRCUIT JUDGE Electronically Signed by John Bowman Copies Furnished To: Alina Maria Alvarez, E-mail : Alina Maria Alvarez E-mail : , Alina Maria Alvarez E-mail : , Ashley Joseph, E-mail : Ashley Joseph, E-mail : Ashley Joseph, E-mail : *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2020 12:17:02 PM.**** CaseNo: CACE20017636 Page 2 of 2 Kevin Weisser, E-mail : ab@weklaw.com Kevin Weisser, E-mail : pb@weklaw.com Kevin Weisser, E-mail : kw@weklaw.com Sapir Elazar, E-mail : JM@WEKLaw.com Sapir Elazar, E-mail : AB@WEKLaw.com Sapir Elazar, E-mail : SE@WEKLaw.com Filing # 119195918 E-Filed 01/07/2021 08:36:51 AM EXHIBIT "C" IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CAN[ALA LEWIS DIXON, CASE NO.: CACE-20-017636 Plaintiff. VS. UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. I SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY REOUESTS SERVED WITH THE SUMMONS AND COMPLAINT Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ('1Tniversal"), by and through the undersigned counsel, hereby files its Second Motion for Extension of Time to Respond to Plaintiff's Complaint and Discovery Requests served with the Summons and Complaint, and states as follows: 1. This matter arises out ofa claim asserted by CAMALA LEWIS DIXON ("Plaintiff') against Universal for damages arising out of and resulting from alleged damage occurring on September 10, 2017. 2. The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery Requests, however, additional time is necessary to respond and as such, Universal would respectfully requests an additional thirty (30) days from the date of this Motion to review the file, discuss early resolution, and ifnecessary, file a responsivepleading to Plaintiffs Complaint and an additional twenty (20) days thereafterto respond to Plaintiff's Discovery Requests. 3. This Motion is not being filed for the purposes of delay and will not prejudice any party. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/07/2021 08:36:51 AM.**** CACE-20-017636 Page 2 of2 WHEREFORE,Universal Propertyand CasualtyInsuranceCompany respectfully requests this Court to enter an Order granting Defendant an additional thirty (30) days to respond to Plaintiff's Complaint and an additional twenty (20) days thereafter to respond to Plaintiff's DiscoveryRequests. CERTIFICATEOF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Kevin Weisser, Esq. *w@weklaw.com;pb@weklaw.com) on January 7,2021. Attorneyfor Defendant Universal Property & Casualty Insurance Company P.O. Box 9388 Fort Lauderdale,Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594WudgesMD,) Facsimile: (954) 958-1262 By: /s/ Alina Maria Alvarez Alina Maria Alvarez, Esq. Florida Bar No. 127087 For Service of Court Documents only: Primary: Secondary: Tertiary: For Scheduling Matters: *Please do not send any inquiries or schedulingmattersto or EXHIBIT "D" Adam Shamir From: Adam Shamir Sent: Monday, March 29, 2021 11:51 AM To: mI0225 Subject: LEWIS DIXON, CAMALA VS UNIVERSAL PROPERTY & CASUALTY Attachments: Motion For Extension Of Time.pdf Hi Alina, I'll be taking over this matter going forward. I see that you filed a second MET on 1/7/21 seeking 30 days to respond to the complaint and 20 days for discovery. I'll agree to a third and final extension of 14 days from today. Please send a proposed order on same. Lastly, there are 3 open suits for this insured (FLZO-0117771,FLZO-0117770, FLZO-0117768-E317) so let me know if your client is interested in a global settlement. Regards, Adam Adam Shamir, Esq. 068--81-r,MW %. 800 East Broward Blvd., Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 - .weklaw.com 1 EXHIBIT "E" From: Kory Luciano To: CC: Adam Shamir Subject: Overdue Responses - CAMALA LEWIS DIXON V UNIVERSAL- CASE NUMBER CACE 20 017636 - CLAIM NUMBER FL20 0117768 E317 Date: Friday, June 4, 2021 5:04:00PM Attachments: image001.png Good Afternoon, I have been charged with review of the court filing relating to the above referenced matter. At this time, the following Motions are pending: Defendant's Second Motion for Extension of Time to Respond to Plaintiffs Complaint and Initial Discovery And Defendant's Motion for Protective Order, as it relates to Plaintiffs Notice of Taking Deposition of Defendant''s Corporate Representative. Attorney Shamir is amenable to entering into a second Agreed Order allowing the Defendant ten (10) days to Respond to the Complaint and responses to Discovery, if your office provides the undersigned with a proposed Agreed Order by 4 pm on Wednesday, June 9, 2021. As far as the pending Motion for Protective Order, I have no issue mutuallycoordinating the deposition. Please have your scheduling assistant provide the undersigned with dates and times to depose the field/independent adjusterand Corporate Representative by 4 pm, Wednesday June 9, 2021. Thank you and have a great day. Kory Luciano Paralegal to Adam Shamir, Esquire Weisser Elazar & Kantor, PLLC 800 East Broward Blvd., Suite 510 Fort Lauderdale, Florida 33301 T: (954) 486-2623 F: (954) 572-8695 www.weklaw.com CONFIDENTIALITY NOTICE:"Thismessage and any attached informationis from Weisser Elazar & Kantor PLLC, and may contain confidentialand/or privileged material. It is intended for receipt and review only by the intended person or entity to which it is addressed. Any review, retransmission, dissemination or other use of this information by persons or entities other than the recipient(s) is unauthorized and prohibited. Any transmission of confidential and/or privileged material to persons or entities other than the intended recipient(s)shall not be construed as a waiverof any privilegeor confidence. If you receivethis transmission in error, please contact the sender by return e-mailand deletethe material." COMPOSITE EXHIBIT "F" From: Melinda Lawson To: Adam Shamir; Korv Luciano CC: Alina Maria Alvarez; Fallen Gardner, F.R.P.; Melinda Lawson Subject: Regarding: CAMALA LEWIS DIXON V. UPCIC (Irma) - Claim No: FL20-0117768-E317 / PAO Complaintand Discovery Date: Tuesday, June 29, 2021 9:10:54AM Attachments: image662000.png DF"s Revised Proposed Order on DF"s Second MEXT.pdf Good Morning, Pursuant to the Defendant's Second Motion for Extension of Time previously filed, attached please find a proposed Agreed Order for your review. I included language regarding Plaintiff's outstanding discovery responses. Please advise if OK to submit to the Court. Please note: There may be a delay in response due to vast amount of e- mails received. Thank you, Melinda Lawson Legal Assistant (W): (954) 958-1200 ext:6716 (Direct): (954) 372-1765 UNIVERSAL A aIm-NX M EVZliumm .I.1...%1 .U=i rS =. .e .j. 11 1, ...%.I. Wl<:KI.. )W Join us and GO GREEN! Go paperless with Universal. ConfidentialityNotice: This e-mail message,including any attachments, is for the sole use of the intended recipient(s)and may contain confidentialand privileged information. Any unauthorized review, use, disclosureor distribution is prohibited.If you are not the intended recipient and received this in error, please contact the sender by reply e-mail. You are hereby notified that the copying, use or distribution of any information or materialstransmittedin or with this message is strictly prohibited. IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CAMALA LEWIS DIXON, CASE NO.: CACE-20-017636-13 Plaintiff, VS. UNIVERSALPROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i AGREED ORDER ON DEFENDANT'S SECOND 1MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY THIS MATTER, having come before the Court on Defendant's Second Motion for Extension of Time to Respondto Plaintiffs Complaint and Discovery, through the agreement of the parties, and the Court having been otherwise advised in the Premises, it is hereby: ORDERED AND ADJUDGED that Defendant's Second Motion for Extension oftime is hereby GRANTED. 1. Defendant shall file a response to Plaintiff's Complaint on or before July 16, 2021. 2. Defendant shall file a response to Plaintiffs Discovery Requests on or before August 6, 2021. 3. Plaintiff shall file a response to Defendant:'s Discovery Requests on or before August 13, 2021. DONE AND ORDERED in Chambers in Broward County, Fort Lauderdale, Florida on this of ,2021. , CIRCUIT COURT JUDGE CACE-20-017636-13 Page 2 of 2 Copies Furnished to: Alina Maria Alvarez, Esq., Attorney for Defendant, and Adam Shamir, Esq., Attorney for Plaintiff, ash@weklaw.com;kl@weklaw.com