On February 23, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Giannone, Giovanne,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
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Filing # 124043837 E-Filed 03/30/2021 04:42:01 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GIOVANNE GIANNONE, CASE NO.: CACE-21-003748
Plaintiff(s),
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFFS’ COMPLAINT AND DISCOVERY RE UESTS
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
(“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plaintiff's Complaint and Discovery Requests, and states as follows:
1. This matter arises out of a claim asserted by the Plaintiff against Universal for damages
arising out of and resulting from an alleged loss occurring on or about November 8, 2020.
2. The undersigned counsel is in receipt of Plaintiffs’ Complaint and Discovery Requests;
however, additional time is necessary to adequately respond and as such, Universal would
respectfully request additional time to review the file and respond to Plaintiff's Complaint.
3. Defendant is requesting an extension of thirty (30) days to respond to Plaintiff's
Complaint and an additional thirty (30) days to respond to Plaintiff's discovery requests.
This Motion is not being filed for the purposes of delay and will not prejudice any party.
WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests
this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/30/2021 04:42:00 PM.****
Plaintiff's Complaint and an additional thirty (30) days to respond to Discovery Requests and any
and all other relief this Court may deem just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Edgar A Kelly, Esq., MORGAN LAW GROUP,
P.A.,(ekelly@morganlawgroup.net and mlg.eservice@morganlawgroup.net); on the 30th day of
March, 2021.
Attorney for Defendant
Universal Property & Casualty Company
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: (954) 958-1262
By: /s/ Tiffany Brown
Tiffany Brown, Esq.
Florida Bar No. 68327
For Service of Court Documents only:
Primary-:upciceservice02@universalproperty.com
Secondary: sr0327@universalproperty.com
Tertiary: Aj0709@universalproperty.com
For Scheduling Matters:
10327@universalproperty.com
*Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com
or upciceservice02@universalproperty.com
Document Filed Date
March 30, 2021
Case Filing Date
February 23, 2021
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Filing # 124043837 E-Filed 03/30/2021 04:42:01 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GIOVANNE GIANNONE, CASE NO.: CACE-21-003748 Plaintiff(s), vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT AND DISCOVERY RE UESTS Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY (“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plaintiff's Complaint and Discovery Requests, and states as follows: 1. This matter arises out of a claim asserted by the Plaintiff against Universal for damages arising out of and resulting from an alleged loss occurring on or about November 8, 2020. 2. The undersigned counsel is in receipt of Plaintiffs’ Complaint and Discovery Requests; however, additional time is necessary to adequately respond and as such, Universal would respectfully request additional time to review the file and respond to Plaintiff's Complaint. 3. Defendant is requesting an extension of thirty (30) days to respond to Plaintiff's Complaint and an additional thirty (30) days to respond to Plaintiff's discovery requests. This Motion is not being filed for the purposes of delay and will not prejudice any party. WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/30/2021 04:42:00 PM.**** Plaintiff's Complaint and an additional thirty (30) days to respond to Discovery Requests and any and all other relief this Court may deem just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Edgar A Kelly, Esq., MORGAN LAW GROUP, P.A.,(ekelly@morganlawgroup.net and mlg.eservice@morganlawgroup.net); on the 30th day of March, 2021. Attorney for Defendant Universal Property & Casualty Company P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: (954) 958-1262 By: /s/ Tiffany Brown Tiffany Brown, Esq. Florida Bar No. 68327 For Service of Court Documents only: Primary-:upciceservice02@universalproperty.com Secondary: sr0327@universalproperty.com Tertiary: Aj0709@universalproperty.com For Scheduling Matters: 10327@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice02@universalproperty.com