On April 06, 2021 a
Party Discovery
was filed
involving a dispute between
Catherine Bilotti,
Joseph Bilotti,
and
United Property And Casualty Insurance Company,
for INSURANCE CLAIM
in the District Court of Palm Beach County.
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Filigg # 119180597 E-Filed 01/06/2021 04:51:15 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE20018750
JOSEPH BILOTTI AND CATHERINE
BILOTTI,
Plaintiffs,
vs.
UNITED PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
COMPLY WITH COURT ORDER
COMES NOW, Defendant, UNITED PROPERTY AND CASUALTY INSURANCE
COMPANY, by and through undersigned counsel, and hereby moves this Honorable Court
to extend the time for Defendant comply with this Court's order rendered on December 8,
2020, and allow Defendant an additional time to serve its response to Plaintiffs’ Complaint,
and states as follows:
1. The Complaint in this matter was served by the Chief Financial Officer of the
State of Florida upon Defendant herein on November 16, 2020.
2. On December 8, 2020, this Court granted Defendant's Motion for Extension
of Time to Respond to Plaintiffs’ Complaint and, per agreement of the parties, ordered
Defendant to serve its response on or before January 6, 2021.
3. Despite the undersigned's diligent efforts, additional time is necessary to file the
appropriate responsive pleading to Plaintiffs’ Complaint. In this regard, Defendant would
*** FILED: BROWARD COUNTY, FL_BRENDA D. FORMAN, CLERK 01/06/2021 04:51:15 PM.****
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4/6/2021 2:31:09 PMask this Court to extend the time for Defendant to comply with this Court’s order and allow
Defendant an additional time to respond to Plaintiffs’ Complaint.
4. No prejudice will be occasioned by any party should the Court grant the
aforementioned requested relief and allow Defendant additional time to file a responsive
pleading.
5. This motion is not made for the purposes of undue delay.
WHEREFORE, Defendant, herein, respectfully requests this Honorable Court to
enter an order extending the time for Defendant to comply with this Court’s order rendered
on December 8, 2020, and allow Defendant an additional time to serve its response to
Plaintiffs’ Complaint.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
by e-mail to Valorie Ss. Chavin, propertyservice@cmslawgroup.com;
vchavin@cmslawgroup.com; CHAVIN MITCHELL SHMUELY, 12955 Biscayne Boulevard,
Suite 201, North Miami, FL 33181, 866/345-2033, this 6" day of January, 2021.
By_/s/ Ailene S. Rogers
AILENE S. ROGERS
Florida Bar # 964379
PETERSON BERNARD
Attorneys for Defendant
707 S.E. 34 Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
ailene rogers@petersonbernard.com
sandy.dodamead@petersonbernard.com
ASRUkqk
123.31945
FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4/6/2021 2:31:09 PM.
Document Filed Date
April 06, 2021
Case Filing Date
April 06, 2021
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Filigg # 119180597 E-Filed 01/06/2021 04:51:15 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE20018750 JOSEPH BILOTTI AND CATHERINE BILOTTI, Plaintiffs, vs. UNITED PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. DEFENDANT’S MOTION FOR EXTENSION OF TIME TO COMPLY WITH COURT ORDER COMES NOW, Defendant, UNITED PROPERTY AND CASUALTY INSURANCE COMPANY, by and through undersigned counsel, and hereby moves this Honorable Court to extend the time for Defendant comply with this Court's order rendered on December 8, 2020, and allow Defendant an additional time to serve its response to Plaintiffs’ Complaint, and states as follows: 1. The Complaint in this matter was served by the Chief Financial Officer of the State of Florida upon Defendant herein on November 16, 2020. 2. On December 8, 2020, this Court granted Defendant's Motion for Extension of Time to Respond to Plaintiffs’ Complaint and, per agreement of the parties, ordered Defendant to serve its response on or before January 6, 2021. 3. Despite the undersigned's diligent efforts, additional time is necessary to file the appropriate responsive pleading to Plaintiffs’ Complaint. In this regard, Defendant would *** FILED: BROWARD COUNTY, FL_BRENDA D. FORMAN, CLERK 01/06/2021 04:51:15 PM.**** FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4/6/2021 2:31:09 PMask this Court to extend the time for Defendant to comply with this Court’s order and allow Defendant an additional time to respond to Plaintiffs’ Complaint. 4. No prejudice will be occasioned by any party should the Court grant the aforementioned requested relief and allow Defendant additional time to file a responsive pleading. 5. This motion is not made for the purposes of undue delay. WHEREFORE, Defendant, herein, respectfully requests this Honorable Court to enter an order extending the time for Defendant to comply with this Court’s order rendered on December 8, 2020, and allow Defendant an additional time to serve its response to Plaintiffs’ Complaint. WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to Valorie Ss. Chavin, propertyservice@cmslawgroup.com; vchavin@cmslawgroup.com; CHAVIN MITCHELL SHMUELY, 12955 Biscayne Boulevard, Suite 201, North Miami, FL 33181, 866/345-2033, this 6" day of January, 2021. By_/s/ Ailene S. Rogers AILENE S. ROGERS Florida Bar # 964379 PETERSON BERNARD Attorneys for Defendant 707 S.E. 34 Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile ailene rogers@petersonbernard.com sandy.dodamead@petersonbernard.com ASRUkqk 123.31945 FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 4/6/2021 2:31:09 PM.