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.
Preview
Filing # 130578130 E-Filed 07/13/2021 04:32:45 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 THE COMPLAINT
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 response to the
Complaint and in support thereof states as follows:
1. The Complaint in this matter was served on CITIZENS on June 23, 2021;
therefore, Citizens response to the Complaint is due July 13, 2021.
2. Undersigned counsel is in need of additional time to prepare its response to
Plaintiff' s Complaint.
3 The requested delay will not prejudice the Plaintiff in this matter.
WHEREFORE, Defendant, Citizens, respectfully requests this Court to grant Defendant's
Motion for Extension o f Time to Respond to the Complaint.
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE1
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 '
Tel: (305) 670-1101 Fax: (305) 670-1161
'
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2021 04:32:44 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-
Mail to: and this 13th day
of July, 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
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 '
Tel: (305) 670-1101 Fax: (305) 670-1161
'
Document Filed Date
July 13, 2021
Case Filing Date
May 28, 2021
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Filing # 130578130 E-Filed 07/13/2021 04:32:45 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 THE COMPLAINT 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 response to the Complaint and in support thereof states as follows: 1. The Complaint in this matter was served on CITIZENS on June 23, 2021; therefore, Citizens response to the Complaint is due July 13, 2021. 2. Undersigned counsel is in need of additional time to prepare its response to Plaintiff' s Complaint. 3 The requested delay will not prejudice the Plaintiff in this matter. WHEREFORE, Defendant, Citizens, respectfully requests this Court to grant Defendant's Motion for Extension o f Time to Respond to the Complaint. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE1 QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ' Tel: (305) 670-1101 Fax: (305) 670-1161 ' *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/13/2021 04:32:44 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- Mail to: and this 13th day of July, 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 QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYSAT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 ' Tel: (305) 670-1101 Fax: (305) 670-1161 '