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 # 125461881 E-Filed 04/22/2021 06:12:54 PM
21-10668
ACA
IN THE CIRCUIT COURT OF THE 17
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JIMMY NOEL, CASE NO. CACE 21-006186 (25)
(Judge Carol-Lisa Phillips)
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW, DEFENDANT, CITIZENS PROPERTY INSURANCE
CORPORATION, and pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure, moves
for an extension of time to respond to Plaintiff's Complaint and as grounds states the following:
1. The above-captioned matter arises out of a homeowner's insurance claim for
alleged property damages.
2. Plaintiff filed a Complaint and Citizens’ response is due on or about April 22,
2021.
3. The undersigned counsel requests an enlargement of time of ten (10) days to
confer with the client, to obtain and review the necessary documents, and to otherwise respond to
Plaintiff's Complaint.
4. No prejudice shall result to any of the parties with the granting of the instant
enlargement of time and this Motion is made in good faith without the purposes of delay.
5. Other grounds to be argued Ore Tenus.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/22/2021 06:12:53 PM.****WHEREFORE, for all the foregoing, the Defendant requests that this Honorable Court
grant its Motion for Extension of Time of ten (10) days and any and all other relief as is deemed
just and reasonable.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
sent by e-mail on this 22nd day of April, 2021, to Kenneth R. Duboff, Esq., Duboff Law Firm,
Attomeys for Plaintiff, courtdocument@dubofflawfirm.com.
BRONSTEIN & CARMONA, P.A.
Attomeys for Defendant
8000 Peters Road, Suite A-200
Fort Lauderdale, FL 33324
(954) 358-0444 — Phone
(954) 358-0445 — Fax
service@bronstein-carmona.com
By: /s/Ana C. Arenas
Ana C. Arenas
Florida Bar No: 1020219
Document Filed Date
April 22, 2021
Case Filing Date
March 25, 2021
Category
Other - Insurance Claim
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Filing # 125461881 E-Filed 04/22/2021 06:12:54 PM 21-10668 ACA IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JIMMY NOEL, CASE NO. CACE 21-006186 (25) (Judge Carol-Lisa Phillips) Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW, DEFENDANT, CITIZENS PROPERTY INSURANCE CORPORATION, and pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure, moves for an extension of time to respond to Plaintiff's Complaint and as grounds states the following: 1. The above-captioned matter arises out of a homeowner's insurance claim for alleged property damages. 2. Plaintiff filed a Complaint and Citizens’ response is due on or about April 22, 2021. 3. The undersigned counsel requests an enlargement of time of ten (10) days to confer with the client, to obtain and review the necessary documents, and to otherwise respond to Plaintiff's Complaint. 4. No prejudice shall result to any of the parties with the granting of the instant enlargement of time and this Motion is made in good faith without the purposes of delay. 5. Other grounds to be argued Ore Tenus. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/22/2021 06:12:53 PM.****WHEREFORE, for all the foregoing, the Defendant requests that this Honorable Court grant its Motion for Extension of Time of ten (10) days and any and all other relief as is deemed just and reasonable. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been sent by e-mail on this 22nd day of April, 2021, to Kenneth R. Duboff, Esq., Duboff Law Firm, Attomeys for Plaintiff, courtdocument@dubofflawfirm.com. BRONSTEIN & CARMONA, P.A. Attomeys for Defendant 8000 Peters Road, Suite A-200 Fort Lauderdale, FL 33324 (954) 358-0444 — Phone (954) 358-0445 — Fax service@bronstein-carmona.com By: /s/Ana C. Arenas Ana C. Arenas Florida Bar No: 1020219