Motion for Extension of Time - Party: Defendant Universal Property & Casualty Insurance Company - NaTasha Thompson Plaintiff vs. Universal Property & Casualty Insurance Company Defendant

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On April 16, 2021 a 3 case was filed by Thompson, Natasha, represented by Molina, Mario I, against Universal Property & Casualty Insurance Company, represented by Bosch, Jose E, in the jurisdiction of Broward County. Judge Haimes, David A. presiding.

                        
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                          Filing # 127244236 E-Filed 05/20/2021 05:12:45 PM

IN THE CIRCUIT COURT OF THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NATASHA THOMPSON, CASE NO.: CACE-21-007730
Plaintiff,

v.

UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,

Defendant.
/

DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT

Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, by and
through the undersigned counsel, and pursuant to the applicable Rules of Civil Procedure, hereby
files its Motion for Extension of Time to Respond to Plaintiffs’ Complaint and in support thereof
states as follows:

1. A response to Plaintiff's Complaint is due on May 20, 2021.

2. The undersigned counsel was recently engaged to represent Defendant in this matter
and is in need of additional time within which to prepare its response to Plaintiff's Complaint.

3. The undersigned counsel contacted Plaintiff's counsel in an attempt to reach an
agreement on an enlargement of time.

4. The under…