Motion,Ex Parte: Eduardo Africano, et al Plaintiff vs. United Property And Casualty Insurance Company Defendant

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                                Filing #   134879030 E-Filed 09/20/2021 10:25:36 AM




                             IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
                                          IN AND FOR BROWARD COUNTY, FLORIDA


                                                                          GENERAL JURISDICTIONDIVISION
                                                                          CASE NO. CACE-21-010708
           EDUARDO AFRICANO,


                      Plaintiff.
           VS.



           UNITED PROPERTY & CASUALTY
           INSURANCE COMPANY,
           a   Florida corporation,


                      Defendant.


                     PLAINTIFFS' MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
                                                     DEFENDANT'S DISCOVERY


                      COMES        NOW, Plaintiff, Eduardo Africano, by and through undersigned counsel, hereby

           files this Motion for      Enlargement of Time to Respond to        Defendant's Discovery (the      "Motion")

           and in support     thereof, states as follows:

                      1.       On    or   about   August 18, 2021,   Plaintiff was served with Defendant's First Set of


           Interrogatories and First Request for Production of Documents (the "Discovery").

                      2.      Plaintiffs response to the      Discovery is due on or about September 17,2021.

                      3       In order to    properly respond to     Defendant's Discovery, Plaintiffneeds additional


           time to    gather the requested        documentationand review the request    so as   to   provide complete   and


           accurate responses.


                      4.      This Motion is       brought in good faith and not for the purposes of delay.

                      5.      This    enlargement of time will not prejudice Defendant.

                      6.      Accordingly,        the   undersigned respectfully requests   this Honorable Court for


           additional      time, pursuant     to Florida Rule of     Civil Procedure 1.090, within which        to   provide

           responses to Defendant's discovery requests.




           Matter ID: 12806



               ***
                     FILED: BROWARD COUNTY, FL BRENDA D.               FORMAN, CLERK 09/20/2021 10:25:36 AM.****
         WHEREFORE, Plaintiff respectfully requests this              Honorable Court enter    an   Order(a)

providing   an     enlargement   of time in which to       respond   to Defendant's    Discovery,   and   (b)

granting such other      and further relief as this Court deems just and proper.


                                       CERTIFICATE OF SERVICE


                   I HEREBY CERTIFY that           on   September 20, 2021,    a   true and correct copy of
the   foregoing    was   emailed to:    Kathryn   M.   Winkler, Esq.,
                                         Counsel for the Defendant.


                                                   Respectfully submitted,

                                                   /s/ Dustin Hite
                                                   Florida Professional Law     Group, PLLC
                                                   Dustin Hite,   Esq.
                                                   Florida Bar No. 1002251
                                                   4600 Sheridan     St., Suite 303
                                                   Hollywood, FL 33021
                                                   Tel. (954) 284-0900
                                                   Fax. (954) 284-0747
                                                   E-mail: dhite@flplg.corn
                                                   E-mail: eservice@flplg.com
                                                   Attorneys for Plaintiff, Eduardo Africano




Matter ID: 12806