On February 23, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Valentine, Steven R.,
and
Progressive Property Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing # 127015753 E-Filed 05/18/2021 11:45:39 AM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT, IN AND
STEVEN R. VALENTINE, FOR BROWARD COUNTY, FLORIDA
Plaintiff, CASE NO.: CACE-21-003854
Vv.
PROGRESSIVE PROPERTY
INSURANCE COMPANY F/K/A
ARK ROYAL INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO
iD TO DEFENDANT’S DISCOVERY REQU ‘Ss
Plaintiff, STEVEN R. VALENTINE, (hereinafter “Plaintiff’), by and through undersigned
counsel, pursuant to Florida law, hereby file this Motion for Extension of Time to Respond to the,
Defendant’s First Set of Interrogatories, and Defendant’s Request for Production, (hereinafter
“Discovery Requests”) served by Defendant, PROGRESSIVE PROPERTY INSURANCE
COMPANY F/K/A ARK ROYAL INSURANCE COMPANY (“Defendant”). In support thereof,
Plaintiff hereby states as follows:
1 On April 19, 2021, Plaintiff was served with Defendant’s First Set of Interrogatories,
and Defendant’s Request for Production (“Defendant’s Discovery Requests”).
Plaintiff requires additional time within which to confer with counsel, in order to
properly respond to Defendant’s Discovery Requests.
Plaintiff's request for an extension of time will not prejudice Defendant in this action.
Plaintiff’s request is not made for the purpose of delay.
WHEREFORE Plaintiff, STEVEN R. VALENTINE, respectfully requests that this
Honorable Court grant their Motion for Extension of Time to Respond to Defendant’s Discovery
Page 1 of 2
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/18/2021 11:45:38 AM.*###*
Requests, and for any other relief this Court deems fair and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above foregoing has been sent
via email to BECK LAW, P.A., Nathan Weinbaum, Esq. at. pleadings@becklawpa.com ;
weinbaum@becklawpa.com and beck@becklawpa.com on this 18" day of May, 2021.
HL LAW GROUP, P.A.
By: /s/Daniel Rosenbaum
Daniel Rosenbaum, Esquire
FBN: 123674
Harold Levy, Esquire
FBN: 30478
Attomey for Plaintiff(s)
2601 E. Oakland Park Blvd, #503
Fort Lauderdale, Florida 33306
Telephone: (954) 713-1212
Facsimile: (954) 760-4239
Email: Service@HLLawGroup.com
Secondary Email:
DRosenbaum@HLLawGroup.com
SJames@HLLawGroup.com
Page 2 of 2
Document Filed Date
May 18, 2021
Case Filing Date
February 23, 2021
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