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.
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Filing # 124526652 E-Filed 04/07/2021 07:44:07 PM
STEVEN R. VALENTINE, IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
Plaintiff, BROWARD COUNTY, FLORIDA
vs.
CASE NO.: CACE-21-003854
PROGRESSIVE PROPERTY
INSURANCE COMPANY,
Defendant.
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S COMPLAINT
Comes Now, Defendant, PROGRESSIVE PROPERTY INSURANCE
COMPANY, (“Defendant”), by and through the undersigned attorney and hereby files
this Motion for Extension of Time to Respond to Plaintiff's Complaint and as grounds
states as follows:
1. Defendant was recently served with Plaintiff's Complaint in the above-captioned
matter.
2. Defendant requires additional time to review and evaluate said documents in
order to properly respond.
3. The purpose of this Motion is not to delay; it is in the interest of justice.
4. Plaintiff will not be prejudiced by this Court granting Defendant’s Motion.
WHEREFORE, Defendant, PROGRESSIVE PROPERTY INSURANCE COMPANY,
respectfully requests this Honorable Court to enter an order granting this Motion and
allowing Defendant an additional thirty (30) days from the date of the Order within which
to file a response to Plaintiff's Complaint.
Certificate of Service located on the following page.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/07/2021 07:44:06 PM.**#*
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was
furnished via the e-portal to: Daniel Rosenbaum, Esq., 2601 East Oakland Park
Boulevard, Suite 503, Fort Lauderdale, Florida 33306;
(DRosenbaum@HLLawgroup.com; Service@HLLawgroup.com;
SJames@HLLawGroup.com) on April 7, 2021.
BECK LAW, P.A.
901 Clint Moore Road, Suite C
Boca Raton, FL 33487
Tel: (561) 990-1647
Fax: (561) 717-9673
By: /s/ NATHAN WEINBAUM, ESQ.
Florida Bar No.: 1025784
Primary E-Mail: pleadings@becklawpa.com
Secondary E-Mail: weinbaum@becklawpa.com
beck@becklawpa.com
Attorney for Defendant
Document Filed Date
April 07, 2021
Case Filing Date
February 23, 2021
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Filing # 124526652 E-Filed 04/07/2021 07:44:07 PM STEVEN R. VALENTINE, IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR Plaintiff, BROWARD COUNTY, FLORIDA vs. CASE NO.: CACE-21-003854 PROGRESSIVE PROPERTY INSURANCE COMPANY, Defendant. DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Comes Now, Defendant, PROGRESSIVE PROPERTY INSURANCE COMPANY, (“Defendant”), by and through the undersigned attorney and hereby files this Motion for Extension of Time to Respond to Plaintiff's Complaint and as grounds states as follows: 1. Defendant was recently served with Plaintiff's Complaint in the above-captioned matter. 2. Defendant requires additional time to review and evaluate said documents in order to properly respond. 3. The purpose of this Motion is not to delay; it is in the interest of justice. 4. Plaintiff will not be prejudiced by this Court granting Defendant’s Motion. WHEREFORE, Defendant, PROGRESSIVE PROPERTY INSURANCE COMPANY, respectfully requests this Honorable Court to enter an order granting this Motion and allowing Defendant an additional thirty (30) days from the date of the Order within which to file a response to Plaintiff's Complaint. Certificate of Service located on the following page. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 04/07/2021 07:44:06 PM.**#* CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the e-portal to: Daniel Rosenbaum, Esq., 2601 East Oakland Park Boulevard, Suite 503, Fort Lauderdale, Florida 33306; (DRosenbaum@HLLawgroup.com; Service@HLLawgroup.com; SJames@HLLawGroup.com) on April 7, 2021. BECK LAW, P.A. 901 Clint Moore Road, Suite C Boca Raton, FL 33487 Tel: (561) 990-1647 Fax: (561) 717-9673 By: /s/ NATHAN WEINBAUM, ESQ. Florida Bar No.: 1025784 Primary E-Mail: pleadings@becklawpa.com Secondary E-Mail: weinbaum@becklawpa.com beck@becklawpa.com Attorney for Defendant