On October 14, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Hernandez, Arleni Rivero,
Hernandez, Ernesto Pupo,
Rivero, Anisleydis Pupo,
and
Almeida, Eduardo R.,
Almeida, Fabricio Rubio,
for Auto Negligence
in the District Court of Miami-Dade County.
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Filing # 140854602 E-Filed 12/22/2021 03:18:01 PM
ARLENI RIVERO HERNANDEZ, IN THE 11TH JUDICIAL CIRCUIT COURT
ERNESTO PUPO HERNANDEZ AND IN AND FOR MIAMI DADE COUNTY,
ANISLEYDIS PUPO RIVERO FLORIDA
PLAINTIFF,
V. CASE NO. 2021-023121-CA-01
FABRICIO RUBIO ALMEIDA & FLORIDA BAR NO. 1019747
EDUARDO R. ALMEIDA
DEFENDANT.
______________________________________/
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANT’S REQUESTS FOR PRODUCTION AND FIRST SET OF
INTERROGATORIES
COMES NOW, the Plaintiff, ANISLEYDIS PUPO RIVERO by and through the
undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090(b), hereby files this
Motion for Extension of Time to Respond to Defendant’s Requests for Production and First Set of
Interrogatories and in support thereof, states as follows:
1. The full materials needed to reply to both documents are currently not yet in the
possession of Plaintiff’s counsel and Plaintiff’s counsel needs time to consult with its client in
order to prepare discovery responses.
2. In the event this motion is denied, in an abundance of caution, the Plaintiff hereby
raises timely objections to each and every Request for Production and Interrogatory on the grounds
that the information request is overbroad, irrelevant, harassing, seeks disclosure of confidential
and/or protected proprietary information, seeks documents protected by work product and/or
documents prepared in anticipation of litigation and is not reasonably calculated to lead to
admissible evidence. The Plaintiff reserves the right to withdraw and/or amend these objections.
3. Defendant will suffer no prejudice from this extension of time.
1150 NW 72nd Avenue, Suite 600, Miami, Florida 33126
Telephone: (305) 760-9085 ∙ Facsimile: (786) 800-3611 ∙ Toll Free: (888) 450-4909
WHEREFORE, the Plaintiff, ANISLEYDIS PUPO RIVERO, respectfully requests that
this Court grant Plaintiff additional time to file responses and amended objections to Defendant’s
discovery requests and any other or further relief deemed just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed to:
Alexandra M. De Maio, The Law Office of Robert P. Kelly, P.O. Box 7217, London, KY 40742,
PLGMail@libertymutual.com; alexandra.demaio@libertymutual.com, on December 22, 2021.
Pacin Levine, P.A.
Attorneys for Plaintiff
1150 NW 72nd Avenue, Suite 600
Miami, FL 33126
(305) 760-9085- Telephone
(786) 800-3611- Facsimile
By: Signed electronically to avoid delay
Claudia E. Perez, Esq.
Florida Bar No. 1019747
Pleadings Email: bipleadings@pl-law.com
1150 NW 72nd Avenue, Suite 600, Miami, Florida 33126
Telephone: (305) 760-9085 ∙ Facsimile: (786) 800-3611 ∙ Toll Free: (888) 450-4909
Document Filed Date
December 22, 2021
Case Filing Date
October 14, 2021
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Filing # 140854602 E-Filed 12/22/2021 03:18:01 PM ARLENI RIVERO HERNANDEZ, IN THE 11TH JUDICIAL CIRCUIT COURT ERNESTO PUPO HERNANDEZ AND IN AND FOR MIAMI DADE COUNTY, ANISLEYDIS PUPO RIVERO FLORIDA PLAINTIFF, V. CASE NO. 2021-023121-CA-01 FABRICIO RUBIO ALMEIDA & FLORIDA BAR NO. 1019747 EDUARDO R. ALMEIDA DEFENDANT. ______________________________________/ PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S REQUESTS FOR PRODUCTION AND FIRST SET OF INTERROGATORIES COMES NOW, the Plaintiff, ANISLEYDIS PUPO RIVERO by and through the undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090(b), hereby files this Motion for Extension of Time to Respond to Defendant’s Requests for Production and First Set of Interrogatories and in support thereof, states as follows: 1. The full materials needed to reply to both documents are currently not yet in the possession of Plaintiff’s counsel and Plaintiff’s counsel needs time to consult with its client in order to prepare discovery responses. 2. In the event this motion is denied, in an abundance of caution, the Plaintiff hereby raises timely objections to each and every Request for Production and Interrogatory on the grounds that the information request is overbroad, irrelevant, harassing, seeks disclosure of confidential and/or protected proprietary information, seeks documents protected by work product and/or documents prepared in anticipation of litigation and is not reasonably calculated to lead to admissible evidence. The Plaintiff reserves the right to withdraw and/or amend these objections. 3. Defendant will suffer no prejudice from this extension of time. 1150 NW 72nd Avenue, Suite 600, Miami, Florida 33126 Telephone: (305) 760-9085 ∙ Facsimile: (786) 800-3611 ∙ Toll Free: (888) 450-4909 WHEREFORE, the Plaintiff, ANISLEYDIS PUPO RIVERO, respectfully requests that this Court grant Plaintiff additional time to file responses and amended objections to Defendant’s discovery requests and any other or further relief deemed just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed to: Alexandra M. De Maio, The Law Office of Robert P. Kelly, P.O. Box 7217, London, KY 40742, PLGMail@libertymutual.com; alexandra.demaio@libertymutual.com, on December 22, 2021. Pacin Levine, P.A. Attorneys for Plaintiff 1150 NW 72nd Avenue, Suite 600 Miami, FL 33126 (305) 760-9085- Telephone (786) 800-3611- Facsimile By: Signed electronically to avoid delay Claudia E. Perez, Esq. Florida Bar No. 1019747 Pleadings Email: bipleadings@pl-law.com 1150 NW 72nd Avenue, Suite 600, Miami, Florida 33126 Telephone: (305) 760-9085 ∙ Facsimile: (786) 800-3611 ∙ Toll Free: (888) 450-4909