On February 23, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Goncalves, Ricardo,
Monasterio, Carla,
and
Zortam, Llc,,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
Preview
Filing # 125714561 E-Filed 04/27/2021 05:01:56 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO: 2021-0003741 Div. 14
RICARDO GONCALVES and
CARLA MONASTERIO, spouse,
Plaintiffs,
vs.
ZORTAM, LLC,
Defendant.
/
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
TO RESPOND TO DEFENDANT’S DISCOVERY
COMES NOW, Plaintiffs, RICARDO GONCALVES and CARLA MONASTERIO,
spouse, by and through its undersigned counsel, pursuant to Florida Rule of Civil Procedure
1.090(b), files its Motion for Extension of Time to Respond to Defendant’s Discovery and in
support thereto, states as follows:
1. Defendant served Interrogatories and Request for Production upon Plaintiffs,
Ricardo Goncalves and Carla Monasterio, on March 30th, 2021.
2. The Plaintiffs need additional time within which to respond to Defendant’s
Interrogatories and Request for Production.
3. An extension of time is requested to afford counsel for Plaintiffs sufficient time to
complete its responses, including any objections, to the pending discovery.
4. This Motion is not made for purposes of delay and should this Motion be granted;
no parties will be prejudiced.
WHEREFORE, Plaintiffs, RICARDO GONCALVES and CARLA MONASTERIO,
spouse, by and through undersigned counsel, respectfully request this Honorable Court grant this
Motion for Extension of Time to Respond to Plaintiffs Discovery.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/27/2021 05:01:56 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of the foregoing has been served via Electronic Mail
on April 27th, 2021 to: Jaime A. Pozo, Esq., POZO-DIAZ & POZO, P.A., Attorneys for
Defendant [ eservice@pdplawyers.com, jmello@pdplawyers.com, rsuarez@pdplawyers.com ]
[sl Seamie Re. Martin, Eig
JAMIE R. MARTIN, ESQ.
Florida Bar No. 94024
CINDY A. GOLDSTEIN, P.A.
10100 W. Sample Road, Suite 200
Coral Springs, Florida 33065
(954) 346-5420 (Phone)
(954) 346-5419 (Facsimile)
pleadings@cindygoldsteinlaw.com
Document Filed Date
April 27, 2021
Case Filing Date
February 23, 2021
Category
Neg - Premises Liability Commercial
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Filing # 125714561 E-Filed 04/27/2021 05:01:56 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: 2021-0003741 Div. 14 RICARDO GONCALVES and CARLA MONASTERIO, spouse, Plaintiffs, vs. ZORTAM, LLC, Defendant. / PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY COMES NOW, Plaintiffs, RICARDO GONCALVES and CARLA MONASTERIO, spouse, by and through its undersigned counsel, pursuant to Florida Rule of Civil Procedure 1.090(b), files its Motion for Extension of Time to Respond to Defendant’s Discovery and in support thereto, states as follows: 1. Defendant served Interrogatories and Request for Production upon Plaintiffs, Ricardo Goncalves and Carla Monasterio, on March 30th, 2021. 2. The Plaintiffs need additional time within which to respond to Defendant’s Interrogatories and Request for Production. 3. An extension of time is requested to afford counsel for Plaintiffs sufficient time to complete its responses, including any objections, to the pending discovery. 4. This Motion is not made for purposes of delay and should this Motion be granted; no parties will be prejudiced. WHEREFORE, Plaintiffs, RICARDO GONCALVES and CARLA MONASTERIO, spouse, by and through undersigned counsel, respectfully request this Honorable Court grant this Motion for Extension of Time to Respond to Plaintiffs Discovery. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/27/2021 05:01:56 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of the foregoing has been served via Electronic Mail on April 27th, 2021 to: Jaime A. Pozo, Esq., POZO-DIAZ & POZO, P.A., Attorneys for Defendant [ eservice@pdplawyers.com, jmello@pdplawyers.com, rsuarez@pdplawyers.com ] [sl Seamie Re. Martin, Eig JAMIE R. MARTIN, ESQ. Florida Bar No. 94024 CINDY A. GOLDSTEIN, P.A. 10100 W. Sample Road, Suite 200 Coral Springs, Florida 33065 (954) 346-5420 (Phone) (954) 346-5419 (Facsimile) pleadings@cindygoldsteinlaw.com