On May 24, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Gobstein, Elaine,
and
Tower Hill Prime Insuance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 133336697 E-Filed 08/24/2021 06:07:56 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL
CIRCUIT
IN
AND
FOR
BROWARD COUNTY, FLORIDA
Case No.: CACE21-010388
ELAINE GOBSTEIN,
Plaintiff.
V
TOWER
HILL
PRIME
INSURANCE
COMPANY,
Defendant.
DEFENDANT'S MOTION FOR EXTENSIONOF TIME TO RESPOND TO
PLAINTIFF'S COMPLAINT AND DISCOVERY REQUESTS
The Defendant, TOWER HILL PRIME INSURANCE COMPANY, files this Motion for
Extension of time to Respond to Plaintiff, ELAINE GOBSTEIN, Complaint and discovery requests
and, in support, states as follows:
1.
Plaintiff's Complaint, Request for Admissions,First Request for Production and First
Set of Interrogatories was served upon Defendant on June 3,2021.
2.
Due to the press of other business, Defendant requires an enlargement of time to
prepare its responses to the afore-mentioned discovery requests.
3.
There should be no prejudice to any party by the granting of this enlargementoftime.
4.
Undersigned counsel will confer with Plaintiff's counsel prior to the date this motion
is heard in an effort to reach an agreement to the extension.
5.
Defendant's said request is made in good faith, in an abundance of caution, and is not
intended to delay action in this matter.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/24/2021 06:07:28 PM.****
Case No.. CACE21-010388
The Defendant, TOWER HILL PRIME INSURANCE COMPANY, respectfully requests
that the Honorable Court enter an Order granting this Motion for Extension of Time to Respond to
Plaintiff's Complaint, Request for Admissions,First Request for Production, and Interrogatories, and
grant any further reliefthis Court deems just and proper under the circumstances.
CERTIFICATEOF SERVICE
I HEREBY CERTIFY that on the 24th day of August, 2021, this document was filed using
the Florida Courts E-Filing Portal. This document is being served on all counsel and pro se parties of
record by the Florida Courts E-Filing Portal, pursuant to and in compliance with Fla. R. Jud. Admin.
2.516. The mailing and electronic addresses are: Michael D. Leader, Esquire, Leader, Leader &
Zucker, PLLC,
633 South Andrews Avenue, Suite 201, Fort Lauderdale,
FL 33301, (954) 523-2020/(954)523-2525 (F), Attorney for Plaintiff, Elaine Gobstein.
KELLEY KRONENBERG
isl Jordan H Lande
Jordan H Lande, Esq.
Fla. Bar No.: 123585
Derek 0. Goldsmith, Esquire
Fla. Bar No. 91111
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for Tower Hill Prime Insurance Co.
Address for service ofpleadings only:
2
Document Filed Date
August 24, 2021
Case Filing Date
May 24, 2021
Category
Other - Insurance Claim
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Filing # 133336697 E-Filed 08/24/2021 06:07:56 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE21-010388 ELAINE GOBSTEIN, Plaintiff. V TOWER HILL PRIME INSURANCE COMPANY, Defendant. DEFENDANT'S MOTION FOR EXTENSIONOF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT AND DISCOVERY REQUESTS The Defendant, TOWER HILL PRIME INSURANCE COMPANY, files this Motion for Extension of time to Respond to Plaintiff, ELAINE GOBSTEIN, Complaint and discovery requests and, in support, states as follows: 1. Plaintiff's Complaint, Request for Admissions,First Request for Production and First Set of Interrogatories was served upon Defendant on June 3,2021. 2. Due to the press of other business, Defendant requires an enlargement of time to prepare its responses to the afore-mentioned discovery requests. 3. There should be no prejudice to any party by the granting of this enlargementoftime. 4. Undersigned counsel will confer with Plaintiff's counsel prior to the date this motion is heard in an effort to reach an agreement to the extension. 5. Defendant's said request is made in good faith, in an abundance of caution, and is not intended to delay action in this matter. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/24/2021 06:07:28 PM.**** Case No.. CACE21-010388 The Defendant, TOWER HILL PRIME INSURANCE COMPANY, respectfully requests that the Honorable Court enter an Order granting this Motion for Extension of Time to Respond to Plaintiff's Complaint, Request for Admissions,First Request for Production, and Interrogatories, and grant any further reliefthis Court deems just and proper under the circumstances. CERTIFICATEOF SERVICE I HEREBY CERTIFY that on the 24th day of August, 2021, this document was filed using the Florida Courts E-Filing Portal. This document is being served on all counsel and pro se parties of record by the Florida Courts E-Filing Portal, pursuant to and in compliance with Fla. R. Jud. Admin. 2.516. The mailing and electronic addresses are: Michael D. Leader, Esquire, Leader, Leader & Zucker, PLLC, 633 South Andrews Avenue, Suite 201, Fort Lauderdale, FL 33301, (954) 523-2020/(954)523-2525 (F), Attorney for Plaintiff, Elaine Gobstein. KELLEY KRONENBERG isl Jordan H Lande Jordan H Lande, Esq. Fla. Bar No.: 123585 Derek 0. Goldsmith, Esquire Fla. Bar No. 91111 10360 West State Road 84 Fort Lauderdale, FL 33324 Telephone: (954) 370-9970 Facsimile: (954) 382-1988 Attorneys for Tower Hill Prime Insurance Co. Address for service ofpleadings only: 2