On April 16, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Kassam, Laila,
and
Fednat Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 126535301 E-Filed 05/11/2021 08:11:24 AM
IN THE CIRCUIT COURT OF THE 17%
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY FLORIDA
CASE NO: CACE-21-007731
LAILA KASSAM,
Plaintiffs),
vs.
FEDNAT INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S COMPLAINT AND DISCOVERY SERVED WITH THE COMPLAINT
COMES NOW the Defendant, FEDNAT INSURANCE COMPANY, (hereinafter
“FEDNAT”), by and through the undersigned attorney and hereby files this Motion for Extension
of Time to Respond to Plaintiff's Complaint and Discovery Served with the Complaint and as
grounds states as follows:
1. FEDNAT was recently served with the Complaint and discovery in the form of Request
for Production, and Interrogatories.
2. FEDNAT requests additional time to respond to the Complaint and additional time to
respond to the aforementioned discovery.
3. The purpose of this motion is not to delay; it is in the interest of justice.
4. Plaintiff will not be prejudiced by the Court granting Defendant’s Motion.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/11/2021 08:11:23 AM.****WHEREFORE the Defendant, FEDNAT INSURANCE COMPANY, respectfully
requests this Honorable Court to enter an order granting the requested extension of time for the
Defendant to file a response to Plaintiff's Complaint and Discovery Served with the Complaint.
CERTIFICATE OF SERVICE
J hereby certify that a true and correct copy of the foregoing has been furnished to Jose
Aguirre, Esq. of lowercase, PLLC using the Florida Courts E-Filing Portal, to
Jose@lowercaselaw.com, on this Tuesday, May 11, 2021.
Attorney for FedNat Insurance Company
F/K/A Federated National Insurance Company
14050 NW 14th Street, Suite 180
Sunrise, FL 33323
Phone: 1-800-293-2532 Ext. 3387
E-mail: pleadings@fednat.com
Kibrown@fednat.com
/s/_ Kimberley S. Brown
KIMBERLEY S. BROWN, ESQUIRE
FL Bar No. 13294
Document Filed Date
May 11, 2021
Case Filing Date
April 16, 2021
Category
Contract and Indebtedness
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Filing # 126535301 E-Filed 05/11/2021 08:11:24 AM IN THE CIRCUIT COURT OF THE 17% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY FLORIDA CASE NO: CACE-21-007731 LAILA KASSAM, Plaintiffs), vs. FEDNAT INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT AND DISCOVERY SERVED WITH THE COMPLAINT COMES NOW the Defendant, FEDNAT INSURANCE COMPANY, (hereinafter “FEDNAT”), by and through the undersigned attorney and hereby files this Motion for Extension of Time to Respond to Plaintiff's Complaint and Discovery Served with the Complaint and as grounds states as follows: 1. FEDNAT was recently served with the Complaint and discovery in the form of Request for Production, and Interrogatories. 2. FEDNAT requests additional time to respond to the Complaint and additional time to respond to the aforementioned discovery. 3. The purpose of this motion is not to delay; it is in the interest of justice. 4. Plaintiff will not be prejudiced by the Court granting Defendant’s Motion. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 05/11/2021 08:11:23 AM.****WHEREFORE the Defendant, FEDNAT INSURANCE COMPANY, respectfully requests this Honorable Court to enter an order granting the requested extension of time for the Defendant to file a response to Plaintiff's Complaint and Discovery Served with the Complaint. CERTIFICATE OF SERVICE J hereby certify that a true and correct copy of the foregoing has been furnished to Jose Aguirre, Esq. of lowercase, PLLC using the Florida Courts E-Filing Portal, to Jose@lowercaselaw.com, on this Tuesday, May 11, 2021. Attorney for FedNat Insurance Company F/K/A Federated National Insurance Company 14050 NW 14th Street, Suite 180 Sunrise, FL 33323 Phone: 1-800-293-2532 Ext. 3387 E-mail: pleadings@fednat.com Kibrown@fednat.com /s/_ Kimberley S. Brown KIMBERLEY S. BROWN, ESQUIRE FL Bar No. 13294