On May 28, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Jyothy, John,
Oonnoonny, John,
and
Citizens Property Insurance Corporation,
for 3
in the District Court of Broward County.
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Filing # 132314718 E-Filed 08/09/2021 04:35:30 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL DIVISION
JOHN OONNOONNY, CASE NO.: CACE-21-010755
Plaintiff.
V
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
i
DEFENDANT'S MOTION FOR EXTENSION OF TIME TO
RESPOND TO DISCOVERY
Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (hereinafter
"CITIZENS"), by and through the undersigned counsel, and pursuant to the applicable Rules of
Civil Procedure, hereby files its Motion for Extension of Time to file its responses to Plaintiffs'
First Request for Production, First Request for Admissions and First Set of Interrogatories and in
support thereof states as follows:
1. Plaintiffs' First Request for Production, First Request for Admissions and First
Set of Interrogatories were served in this matter upon the Defendant on or about June 23,2021.
2. Undersigned counsel is in need of additional time within which to review and
prepare its response to the discovery filed in this matter.
3 The undersigned will confer with the office of Plaintiffs' counsel prior to the date
this motion is heard in an effort to reach an agreement to the extension.
4. The requested delay will not prejudice the Plaintiffs in this matter.
WHEREFORE, Defendant, CITIZENS, respectfully requests this Court to enter an Order
granting Defendant's Motion for Extension of Time to Respond to Discovery.
QU[NTAIROS, PRIETO, WOOD & BOYER, P.A.,ATTORNEYS AT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156Tel: (305) 670-1101 Fax: (305)
' '
670-1161
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/09/2021 04:35:30 PM.****
CASE NO.: CACE-21-010755
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via E-
th
Mail to: and this 9 dayor
August, 2021 to: A. Lee Smith, Esq., at Smith Thompson Law.
QUINTAIROS,PRIETO, WOOD
& BOYER, P.A
th
9300 South Dadeland Boulevard, 4 Floor
Miami, Florida 33156
Telephone: (305) 670-1101
Facsimile: (305) 670-1161
By: /s/ Veronica Rubio
ASIKA PATEL, ESQ.
Florida Bar No. 0581011
VERONICA RUBIO, ESQ.
Florida Bar No. 93002
2
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW
9300 South DadelandBoulevard, 4th Floor, Miami, Florida 33156 Tel: (305) 670-1101 Fax: (305)
' '
670-1161
Document Filed Date
August 09, 2021
Case Filing Date
May 28, 2021
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Filing # 132314718 E-Filed 08/09/2021 04:35:30 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL DIVISION JOHN OONNOONNY, CASE NO.: CACE-21-010755 Plaintiff. V CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. i DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY Defendant, CITIZENS PROPERTY INSURANCE CORPORATION (hereinafter "CITIZENS"), by and through the undersigned counsel, and pursuant to the applicable Rules of Civil Procedure, hereby files its Motion for Extension of Time to file its responses to Plaintiffs' First Request for Production, First Request for Admissions and First Set of Interrogatories and in support thereof states as follows: 1. Plaintiffs' First Request for Production, First Request for Admissions and First Set of Interrogatories were served in this matter upon the Defendant on or about June 23,2021. 2. Undersigned counsel is in need of additional time within which to review and prepare its response to the discovery filed in this matter. 3 The undersigned will confer with the office of Plaintiffs' counsel prior to the date this motion is heard in an effort to reach an agreement to the extension. 4. The requested delay will not prejudice the Plaintiffs in this matter. WHEREFORE, Defendant, CITIZENS, respectfully requests this Court to enter an Order granting Defendant's Motion for Extension of Time to Respond to Discovery. QU[NTAIROS, PRIETO, WOOD & BOYER, P.A.,ATTORNEYS AT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156Tel: (305) 670-1101 Fax: (305) ' ' 670-1161 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/09/2021 04:35:30 PM.**** CASE NO.: CACE-21-010755 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via E- th Mail to: and this 9 dayor August, 2021 to: A. Lee Smith, Esq., at Smith Thompson Law. QUINTAIROS,PRIETO, WOOD & BOYER, P.A th 9300 South Dadeland Boulevard, 4 Floor Miami, Florida 33156 Telephone: (305) 670-1101 Facsimile: (305) 670-1161 By: /s/ Veronica Rubio ASIKA PATEL, ESQ. Florida Bar No. 0581011 VERONICA RUBIO, ESQ. Florida Bar No. 93002 2 QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW 9300 South DadelandBoulevard, 4th Floor, Miami, Florida 33156 Tel: (305) 670-1101 Fax: (305) ' ' 670-1161