Motion,Ex Parte: Kevin Wilson, et al Plaintiff vs. Universal Property & Casualty Ins Co Defendant

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                                Filing # 132218372 E-Filed 08/06/2021 04:17:56 PM
 IN THE CIRCUIT COURT OF THE 177TH
 JUDICIAL CIRCUIT IN AND FOR
 BROWARD COUNTY, FLORIDA
 KEVIN WILSON &
 CASE NO.: CACE-21-011872
 MONICA WILSON#k/a
 MONICA READY,
 Plaintiffs,
 VS.
 UNIVERSALPROPERTY AND CASUALTY
 INSURANCE COMPANY,
 a Florida Corporation,
 Defendant.
 i
 DEFENDANT'S MOTION FOR EXTENSIONOF TIME TO RESPOND
 TO PLAINTIFFS' DISCOVERY REQUESTS
 Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
 ("Universal"), by and through the undersigned counsel, hereby files its Motion for Extension of
 Time to Respondto Plaintiffs' DiscoveryRequests, and states as follows:
 1.
 This matter arises out of a claim asserted by Kevin Wilson and Monica Ready ("Plaintiffs")
 against Universal for damages arising out of and resulting from an alleged loss occurring on or
 about September 10,2017.
 2.
 The undersigned counsel is in rece*t of Plaintiffs' discovery requests; however,
 additional time is necessary to file a response and as such, Universal would respectfully request
 additional time to review the file, discuss early resolution, and ifnecessary, respond to Plaintiffs'
 discovery requests.
 3
 This Motion is not being filed for the purposes of delay and will not prejudice any party.
 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 08/06/2021 04:17:56 PM.****
 KEVIN WILSONANDMONICA READY V. UPCIC
 CASE: CACE-21-011872
 DEFENDANT'SMOTION FOR EXrENSION OF YIMETO RESPONDTO PLAINTIFF'SREQUESTSFOR DISCOVERY
 WHEREFORE, Universal Property and Casualty Insurance Company respectfully
 requests this Court to enter an Order Granting Defendant an additional thirty (30) days to
 respond to Plaintiffs' discovery requests and any and all other relief this Court may deem just
 and proper.
 CERTIFICATE OF SERVICE
 I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
 service to: Dustin A. Hite, Esq., Florida Professional Law Group, PLLC (dhite@flplg.com);
 (lbaday@flplg.com);
 counsel for Plaintiffs, on this
 6TH day ofAugust, 2021.
 AttorneyMDefendant
 UniversalProperty & Casualty Ins. Co.
 PO Box 9388
 Fort Lauderdale,Florida 33310
 Telephone: 954-958-3319
 Toll-Free: 1-833-658-8594(Judges Onlyl
 Facsimile: 954-958-1262
 By-- /s/ Julissa Nethersole
 JulissaNethersole, Esq.
 Fla. Bar No. 97879
 For Service of Court Documents onlv:
 Primary: upciceserviceO 1
 Secondary:
 Tertiary:
 For Scheduling Matters:
 *Please
 do
 not
 send
 any
 inquiries
 or
 scheduling
 matters
 to
 or