On May 24, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Elite Health Investments, Inc,
Usa Medicare Advisors Insurance Agency Llc,
and
Elite Health Investents Inc,
Usa Medicare Advisors Insurance Agency Llc,
for 3
in the District Court of Broward County.
Preview
Filing# 137749260 E-Filed 11/02/2021 03:12:02 PM
USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH
AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR
Company, BROWARD COUNTY, FLORIDA
Plaintiffs, CASE NO: CACE-21-010364
VS.
ELITE HEALTH INVESTMENTS, INC., a
Florida Profit Corporation
Defendant.
DEFENDANT'S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS
The Defendant, ELITE HEALTH INVESTMENTS, INC. ("Defendant"), by and
through the undersigned attorney, hereby files this Motion for Extension of Time to
Respond to Plaintiffs Discovery and as grounds states as follows:
1. Defendant was recently served with Plaintiff's Discovery Requests in the
above-captioned matter.
2. Defendant requires additional time to review and evaluate said documents
in order to properly respond.
3. Defendant requests and additional forty-five(45) days to respond to
Plaintiffs Discovery Requests.
4. The purpose of this motion is not to delay; it is in the interest of justice.
5. Plaintiff will not be prejudiced by the Court granting Defendant's Motion.
WHEREFORE, Defendant, ELITE HEALTH INVESTMENTS, INC, respectfully
requests this Honorable Court to enter an order granting this Motion and allowing
Defendant an additional forty-five
(45) days from the date of the Order within which to file
a response to Plaintiffs Discovery.
Certificate of Service located on the following page
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/02/2021 03:12:01 PM.****
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
via the e-portal to: Veronika Balbuzanova, Esq., Johnson IDalal, 111 N. Pine Island Road,
Suite 103, Plantation, FL 33324; (Vb@Johnsondalal.com; MJ@)JohnsonDalal.corn) on :
November 2, 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/ JOSHUA S. BECK, ESQ.
FloridaBar No.- 040659
Primary E-Mail: pleadinqs@jbecklawpa.corn
Secondary E-Mail: beck@becklawpa.corn
Attorney for Defendant/Counter-Plaintiff
Document Filed Date
November 02, 2021
Case Filing Date
May 24, 2021
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Filing# 137749260 E-Filed 11/02/2021 03:12:02 PM USA MEDICARE ADVISORS INSURANCE IN THE CIRCUIT COURT OF THE 17TH AGENCY LLC, a Florida Limited Liability JUDICIAL CIRCUIT IN AND FOR Company, BROWARD COUNTY, FLORIDA Plaintiffs, CASE NO: CACE-21-010364 VS. ELITE HEALTH INVESTMENTS, INC., a Florida Profit Corporation Defendant. DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS The Defendant, ELITE HEALTH INVESTMENTS, INC. ("Defendant"), by and through the undersigned attorney, hereby files this Motion for Extension of Time to Respond to Plaintiffs Discovery and as grounds states as follows: 1. Defendant was recently served with Plaintiff's Discovery Requests in the above-captioned matter. 2. Defendant requires additional time to review and evaluate said documents in order to properly respond. 3. Defendant requests and additional forty-five(45) days to respond to Plaintiffs Discovery Requests. 4. The purpose of this motion is not to delay; it is in the interest of justice. 5. Plaintiff will not be prejudiced by the Court granting Defendant's Motion. WHEREFORE, Defendant, ELITE HEALTH INVESTMENTS, INC, respectfully requests this Honorable Court to enter an order granting this Motion and allowing Defendant an additional forty-five (45) days from the date of the Order within which to file a response to Plaintiffs Discovery. Certificate of Service located on the following page *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/02/2021 03:12:01 PM.**** CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via the e-portal to: Veronika Balbuzanova, Esq., Johnson IDalal, 111 N. Pine Island Road, Suite 103, Plantation, FL 33324; (Vb@Johnsondalal.com; MJ@)JohnsonDalal.corn) on : November 2, 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/ JOSHUA S. BECK, ESQ. FloridaBar No.- 040659 Primary E-Mail: pleadinqs@jbecklawpa.corn Secondary E-Mail: beck@becklawpa.corn Attorney for Defendant/Counter-Plaintiff