Motion,Ex Parte: John Oonnoonny, et al Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing #   134716619 E-Filed 09/16/2021 10:55:43 AM




                      IN THE CIRCUIT COURT OF THE SEVENTEENTHJUDICIAL CIRCUIT
                                     IN AND FOR BROWARD COUNTY, FLORIDA
                                                           CIVIL DIVISION


           JOHN OONNOONNY
           and JYOTHY         JOHN,                                                  CASE NO: CACE-21-010755


                             Plaintiffs,
           V.




           CITIZENS PROPERTY
           INSURANCE CORPORATION,


                             Defendant.
                                                                   i


            PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY


                       COME NOW the          Plaintiffs,   JOHN OONNOONNY and JYOTHY                          JOHN, by and

           through its undersigned attorneys, and             submit this Motion for Extension of Time to          respond    to



           any written discovery filed/served by the Defendant. In support thereof, the Plaintiffs state:

                       1.    Defendant served First        Request      for   Production,   and   Interrogatories on   Plaintiffs


           on   August 18,   2021.


                       2.    Plaintiffs' responses to Defendant's discovery are             now    due.


                       3     Plaintiffs' counsel requests        an    additional 30   days   to consult with its clients and


           provide responses

                       4.    This motion is not       being   filed for the purpose of delay and will not       prejudice any

           party.

                       WHEREFORE JOHN OONNOONNY and JYOTHY                                  JOHN, respectfully requests this

           Court to enter     an   Order   granting   Plaintiffs   an   additional   thirty (30) days     from the date of the


           Order on this Motion to issue its response to the Defendant's pending written discovery.




                ***
                      FILED: BROWARD COUNTY, FL BRENDA D.                FORMAN, CLERK 09/16/2021 10:55:42 AM.****
                                   CERTIFICATE OF SERVICE


          I HEREBY CERTIFY that          a   true and correct copy of the   foregoing   has been furnished


via Electronic   Mail, pursuant Florida       Rule of Judicial Administration 2.516(b)(1),    through   the


Court's    E-Filing   Portal   System   to: Asika      Petal, Esquire, and Veronica Rubio, Esquire

Quintarios, Prieto, Wood & Boyer, P.A. (Founse! for Citizens Property Insurance

Corporation)    at                                         and                                     on   this

 Ah
16    day of September, 2021.


                                  By:        /s/X Lee Smith
                                             SMITH THOMPSON LAW
                                             A. Lee   Smith, Esquire
                                             FBN:     0031428
                                             Primary
                                             Secondary Email:
                                             4725 N. Lois Avenue
                                             Tampa, Florida 33614
                                             Telephone:      (813) 254-1800
                                             Facsimile:      (813) 254-1844
                                             Attorney for Plaintiffs
ALS/ic