On April 09, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Guerrero, George,
Qureshi, Irma,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing # 128101659 E-Filed 06/04/2021 10:25:05 AM
IN THE CIRCUIT COURT OF THE 17iTH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRMA QURESHI AND
CASE NO.: CACE-21-007238
GEORGE GUERRERO,
Plaintiffs,
VS.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS'
DISCOVERY REQUEST
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
("Universal"),by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plaintiffs' Discoveryrequest and states as follows:
1.
This matter arises out of a claim asserted by Irma Qureshi and George Guerrero
("Plaintiff') against Universal for damages arising out of and resulting from alleged damage
occurring on October 14,2020.
2.
The undersigned counsel is in receipt of Plaintiffs' Discovery requests, however,
additional time is necessary to respond and as such, Universal would respectfully request
additional time to review the file, discuss early resolution, and if necessary, file a response to
Plaintiffs' Discoveryrequest.
3
This Motion is not being filed for the purposes of delay and will not prejudice any
party.
*** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/04/2021 10:25:04 AM.****
Irma Qureshi, et al. vs. UPCIC
CASE NO.: CACE-21-007238
Page 2 of 2
WHEREFORE,UniversalPropertyand CasualtyInsurance Companyrespectfully requests
this Court to enter an Order granting Defendant an additional 30 days to respond to Plaintiffs'
Discoveryrequest.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Amy E. Ruiz, Esq., Francisco Touron, III, Esq., Antonio Villa de Rey, Esq., Taylor
Espino Vega &
Touron,
PLLC,
ARuiz@TEVTlaw.com;
AVRey@TEVTlaw.com;
on the 4th day
ofJune, 2021.
AttorneyMDefendant
Universal Property& Casualty Ins. Co.
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/Joshua Strudwick
Joshua Strudwick,Esq.
Florida Bar No. 95761
For Service of Court Documents onlv:
Primary:
Secondary:
Tertiary:
For Scheduling Matters:
:Please do not send any inquiries or schedulingmatters to
or
2
Document Filed Date
June 04, 2021
Case Filing Date
April 09, 2021
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Filing # 128101659 E-Filed 06/04/2021 10:25:05 AM IN THE CIRCUIT COURT OF THE 17iTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRMA QURESHI AND CASE NO.: CACE-21-007238 GEORGE GUERRERO, Plaintiffs, VS. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS' DISCOVERY REQUEST Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY ("Universal"),by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plaintiffs' Discoveryrequest and states as follows: 1. This matter arises out of a claim asserted by Irma Qureshi and George Guerrero ("Plaintiff') against Universal for damages arising out of and resulting from alleged damage occurring on October 14,2020. 2. The undersigned counsel is in receipt of Plaintiffs' Discovery requests, however, additional time is necessary to respond and as such, Universal would respectfully request additional time to review the file, discuss early resolution, and if necessary, file a response to Plaintiffs' Discoveryrequest. 3 This Motion is not being filed for the purposes of delay and will not prejudice any party. *** FILED: BROWARDCOUNTY, FL BRENDA D. FORMAN, CLERK 06/04/2021 10:25:04 AM.**** Irma Qureshi, et al. vs. UPCIC CASE NO.: CACE-21-007238 Page 2 of 2 WHEREFORE,UniversalPropertyand CasualtyInsurance Companyrespectfully requests this Court to enter an Order granting Defendant an additional 30 days to respond to Plaintiffs' Discoveryrequest. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Amy E. Ruiz, Esq., Francisco Touron, III, Esq., Antonio Villa de Rey, Esq., Taylor Espino Vega & Touron, PLLC, ARuiz@TEVTlaw.com; AVRey@TEVTlaw.com; on the 4th day ofJune, 2021. AttorneyMDefendant Universal Property& Casualty Ins. Co. 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/Joshua Strudwick Joshua Strudwick,Esq. Florida Bar No. 95761 For Service of Court Documents onlv: Primary: Secondary: Tertiary: For Scheduling Matters: :Please do not send any inquiries or schedulingmatters to or 2