Motion,Ex Parte: Amarilis Rodriguez Plaintiff vs. Southern Fidelity Insurance Company Defendant

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                                Filing # 131239856 E-Filed 07/22/2021 04:31:28 PM
 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
 IN AND FOR BROWARD COUNTY, FLORIDA
 AMARILIS RODRIGUEZ,
 CASE NO.: CACE-21-010703
 Plaintiff.
 V
 SOUTHERN FIDELITY
 INSURANCE COMPANY,
 Defendant.
 i
 DEFENDANT, SOUTHERN FIDELITY INSURANCE COMPANY's, MOTION FOR
 EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY
 COMES NOW, Defendant, SOUTHERN FIDELITY INSURANCE COMPANY,
 (hereinafter"SFIC"), pursuantto Fla. R. Civ. P., Rule 1.090(b), herebymoves for an Extension of
 Time to Respond to Plaintiff's Request for Production and Interrogatories,stating as follows:
 1.
 SFIC was served with the Plaintiff's Discovery concurrentwith its Complaint in
 the above-captionedmatter on June 7, 2021.
 2.
 The undersigned requires additional time to meet with its client and review and
 evaluate the facts in order to properlyrespondto Plaintiff's Discovery.
 3
 This motion was not filed for the purpose of causing delay.
 4.
 Granting Defendant's motion will not prejudice Plaintiff, as the lawsuit was
 recentlyfiled.
 5.
 As such, Defendant respectfully moves this Honorable Court for an extension of
 time to respondto the Plaintiff's Discovery.
 WHEREFORE, SOUTHERN FIDELITY INSURANCE COMPANY respectfully
 requests that this Honorable Court enter an Order granting its Motion for Extension of Time to
 Respond to Plaintiff' s Request for Production and Interrogatories,and for any such further relief
 this Court deems proper.
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/22/2021 04:31:27 PM.****
 CASE NO.: CACE-21-010703
 DEFENDANT, SOUTHERNFIDELITYINSURANCE COMPANY's, MOTION FOR EXTENSION OF
 TIME TO RESPOND TO PLAINTIFF'S DISCOVERY
 CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that on this 22nd day of Juk, 2021, I electronically filed the
 foregoing with the Clerk of the Courts by using the ECF system, which will send a notice of
 electronic filing to John S. Bernstein, Esq., of Bernstein Polsky, at service@bpinjury.com.
 Attorneyfor SOUTHERN FIDELITY
 INSURANCE COMPANY, INC.,
 2 S. University Drive, Suite 110
 Plantation, FL 33324
 Phone: (850) 906-1267
 clowe@pmains.com
 By: /s/ ChristineN. Lowe, Esq.
 CHRISTINEN. LOWE, ESQ.
 Florida Bar No.. 95756