On March 25, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Noel, Jimmy,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 133724522 E-Filed 08/31/2021 09:27:41 AM
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
JIMMY NOEL,
CASE NO. CACE-21-006186 Div: 25
Plaintiff,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
MOTION FOR EXTENSION OF TIME
TO COMPLY WITH COURT ORDER
Florida Bar #218261
COMES NOW Plaintiff, by and through the undersigned attorney's and herebyrequest this
Honorable Court for an extension oftime to comply with this court order, and as groundstherefore
would state:
1.
On
July 27,2021
this court entered an order directing Plaintiffto respond to
respond to Interrogatoriesand Request for Production.
2.
While Plaintiff acknowledges and respects the authority of this court to compel
compliance with discovery requests, Plaintiff states, in good faith, that Plaintiff requires an
additional 30 days to properly respond to said discovery.
3
This motion is not made for the purpose ofhindrance or delay, but so that the best
interests ofjusticemay be served by having this action tried on the merits.
4.
Defendant will not be unduly prejudiced by the granting ofthis motion.
WHEREFORE, Plaintiff moves this Honorable Court for a 30 days extension of time to
respond to the above described discovery.
DUBOFF
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 08/31/2021 09:27:41 AM.****
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this
31st
dayor
August
,2021, a
true and correct copyofthe foregoing was emailed electronicallyfiled and servedthroughthe Florida
Court's E-Filing Portal to: Ana C. Arenas, Esq., ofBronstein& Carmona,P.A., 8000 Peters Road,
Suite A-200, Fort Lauderdale,Florida, 33324, at
DUBOFF LAW FIRM
ATTORNEYFOR PLAINTIFF
680 NE 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE
(305) 899-0085
FAX No.
(305) 899-0091
BY-
/S/ KENNETH R. DUBOFF
KENNETH R. DUBOFF
DUBOFF
Document Filed Date
August 31, 2021
Case Filing Date
March 25, 2021
Category
Other - Insurance Claim
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Filing # 133724522 E-Filed 08/31/2021 09:27:41 AM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA JIMMY NOEL, CASE NO. CACE-21-006186 Div: 25 Plaintiff, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. MOTION FOR EXTENSION OF TIME TO COMPLY WITH COURT ORDER Florida Bar #218261 COMES NOW Plaintiff, by and through the undersigned attorney's and herebyrequest this Honorable Court for an extension oftime to comply with this court order, and as groundstherefore would state: 1. On July 27,2021 this court entered an order directing Plaintiffto respond to respond to Interrogatoriesand Request for Production. 2. While Plaintiff acknowledges and respects the authority of this court to compel compliance with discovery requests, Plaintiff states, in good faith, that Plaintiff requires an additional 30 days to properly respond to said discovery. 3 This motion is not made for the purpose ofhindrance or delay, but so that the best interests ofjusticemay be served by having this action tried on the merits. 4. Defendant will not be unduly prejudiced by the granting ofthis motion. WHEREFORE, Plaintiff moves this Honorable Court for a 30 days extension of time to respond to the above described discovery. DUBOFF *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 08/31/2021 09:27:41 AM.**** CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 31st dayor August ,2021, a true and correct copyofthe foregoing was emailed electronicallyfiled and servedthroughthe Florida Court's E-Filing Portal to: Ana C. Arenas, Esq., ofBronstein& Carmona,P.A., 8000 Peters Road, Suite A-200, Fort Lauderdale,Florida, 33324, at DUBOFF LAW FIRM ATTORNEYFOR PLAINTIFF 680 NE 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 FAX No. (305) 899-0091 BY- /S/ KENNETH R. DUBOFF KENNETH R. DUBOFF DUBOFF