Motion to Compel in ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC VS AMERICAN COASTAL INSURANCE COMPANY| Trellis.Law

On June 30, 2021 a Motion,Ex Parte was filed involving a dispute between Arbour Townhouse Condominium Association, Inc, and American Coastal Insurance Company, for Contract & Indebtedness in the District Court of Miami-Dade County.

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Filing # 144578784 E-Filed 02/24/2022 04:52:39 PM

IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA

Case No.: 2021-015633-CA-01

ARBOUR TOWNHOUSE CONDOMINIUM
ASSOCIATION, INC.,

Plaintiff,

AMERICAN COASTAL INSURANCE
COMPANY,

Defendant.
____________________________________/

DEFENDANT'S MOTION TO COMPEL DISCOVERY FROM PLAINTIFF AND
PROTECTICE ORDER AS TO RESCHEDULING DEPOSITION OF DEFENDANT’S
CORPORATE REPRESENTATIVE

Defendant, AMERICAN COASTAL INSURANCE COMPANY (hereinafter

“Defendant”), by and through its undersigned counsel and pursuant to the applicable Florida Rules

of Civil Procedure, hereby files its Motion to Compel Plaintiff, ARBOUR TOWNHOUSE

CONDOMINIUM ASSOCIATION, INC., Responses to Defendant’s First Set of Interrogatories

and First Request for Production, and Protective Order as to Rescheduling Deposition of

Defendant’s Corporate Representative and in support thereof states as follows:

1. On October 25, 2021, Defendant propounded its First Set of Interrogatories and

First Request for Production to Plaintiff, ARBOUR TOWNHOUSE CONDOMINIUM

ASSOCIATION, INC. (See copy of First Set of Interrogatories and First Request for Production

attached hereto as Exhibit “A”).

2. Pursuant to the Florida Rules of Civil Procedure, responses to the aforementioned
CASE NO.: 2021-015633-CA-01

discovery were due from Plaintiff on or before November 24, 2021.

3. On November 24, 2021, Plaintiff filed a Motion for Extension of Time to Respond

to Defendant’s First Set of Discovery.

4. On December 13, 2021, this Honorable Court entered an Agreed Order requiring

Plaintiffs to respond to discovery on or before January 10, 2022. See Court Order attached hereto

as Exhibit “B.”

5. On January 11, 2022, again, Plaintiff filed a Motion for Extension of Time to

Respond to Defendant’s First Set of Discovery.

6. Despite requests, Plaintiff has failed to provide responses or supporting

documents. Plaintiff has also failed to respond to emails concerning the same in a good faith

attempt to obtain the responses.

7. Even more alarming, the deposition of Defendant’s Corporate Representative is set

for March 15, 2021. Defendant advised Plaintiff that their responses will be necessary prior to the

deposition, with enough time to review, so that the Corporate Representative can adequately

speak to defenses in this matter and Defendant can actually know the basis and what is being

claimed in this matter. Defendant brought this to Plaintiff’s attention but has not received any

response. Due to Plaintiff’s actions, Defendant is put in a position where the deposition must be

rescheduled.

8. That being said, Plaintiff’s responses to Interrogatories and Request for Production

are far past due. Furthermore, any and all objections to the pending discovery have been waived.

9. Rule 1.380(a)(4) of the Florida Rules of Civil Procedure provides for an award to the

moving party of the reasonable expenses, including attorney’s fees, incurred in obtaining an Order

compelling responses to discovery requests.

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CASE NO.: 2021-015633-CA-01

WHEREFORE, Defendant, AMERICAN COASTAL INSURANCE COMPANY,

respectfully requests this Court enter the attached proposed Order compelling the Plaintiff to

provide responses to Initial Interrogatories and First Request for Production within five (5) days

and awarding the Defendant attorney’s fees for the preparation, filing and arguing of this Motion,

and granting further relief this Court deems just and proper.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 24th day of February, 2022, this document was served

via Electronic mail to Plaintiff's counsel: Amy E. Ruiz, Esquire, Ruiz | Getman Law, PLLC,

aruiz@ruizgetmanlaw.com, 6800 SW 40th Street, #394, Miami, FL 33155, (305) 978-6311/(305)

397-2760 (F), Attorney for Plaintiff, ARBOUR TOWNHOUSE CONDOMINIUM

ASSOCIATION, INC.

KELLEY KRONENBERG

/s/ Jeremy M. Mishali
Jeremy M. Mishali, Esq.
Fla. Bar No.: 106115
jmishali@kelleykronenberg.com
Jeffrey M. Wank, Esq.
Fla. Bar No.: 68010
jwank@kelleykronenberg.com
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for American Coastal
Insurance Company
Address for service of pleadings only:
jwank@kelleykronenberg.com
jmishali@kelleykronenberg.com
glamchick@kelleykronenberg.com

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EXHIBIT "A"
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA

Case No.: 2021-015633-CA-01

ARBOUR TOWNHOUSE CONDOMINIUM
ASSOCIATION, INC.,

Plaintiff,

AMERICAN COASTAL INSURANCE
COMPANY,

Defendant.
____________________________________/

DEFENDANT’S FIRST SET OF INTERROGATORIES TO PLAINTIFF, ARBOUR
TOWNHOUSE CONDOMINIUM ASSOCIATION, INC.

AMERICAN COASTAL INSURANCE COMPANY (“AMERICAN COASTAL”),

pursuant to Rule 1.340 of the Florida Rules of Civil Procedure propounds the following First Set

of Interrogatories to Plaintiff, ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION,

INC., to be answered within thirty (30) days after service hereof.

DEFINITIONS AND INSTRUCTIONS

1. The terms “you” or “your” shall mean the Plaintiff, ARBOUR TOWNHOUSE
CONDOMINIUM ASSOCIATION, INC.

2. “Person” or “persons” shall mean all natural persons (individual or individuals) and
entities, including without limitation: corporations, companies, partnerships, limited partnerships,
joint ventures, trusts, estates, associations, public agencies, departments, bureaus and boards.

3. The term “relating to” shall mean consists of, refer to, reflect or be in any way
logically or factually connected with the matter discussed, directly or indirectly.

4. The term “document” shall mean any written or graphic matter or other means of
preserving thought or expression, and all tangible things from which information can be processed
or transcribed including the originals and all non-identical copies, whether direct from the original
by reason of any notation made on such copy or otherwise, including, without limitation,
correspondence, memoranda, notes, messages, letters, telegrams, teletype, telefax, bulletins,
meetings or other communications, interoffice and intra-office telephone calls, diaries,
chronological data, minute books, reports, charts, ledgers, invoices, lists, worksheets, receipts,
returns, computer printouts, prospectuses, financial statements, income tax returns, balance sheets,
income statements, ledgers, vouchers, invoices, schedules, affidavits, contracts, agreements,
canceled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases, (and any
and all drafts, alterations and modifications, changes and amendments of any of the foregoing),
graphic or aural records or representations of any kind, including, without limitation, photographs,
charts, graphs, microfiche, microfilm, videotape recordings, motion pictures and electronic,
mechanical or electric recordings or representations of any kind (including, without limitation, e-
mail, tapes, cassettes, disks and recordings).

5. The words “or” as well as “and” shall be construed disjunctively or conjunctively
so as to require the fullest and most complete disclosure of all required information and documents.

6. The term “identify” when used with reference to a natural person means:

a. The full name and address (or, if the current address is not known, the last
known address) of the person.

b. The full name and address of each employer, each corporation of which the
person is an officer or director, and each business in which the person is a
principal.

c. The person’s present (or, if the present is not known, the last known)
position and the position or positions at the time of the act to which the
interrogatory answer relates.

d. Each position the person has ever held with you and the date such positions
were held.

e. Such other information sufficient to provide full identification of the person.

7. The term “identify” when used with reference to any entity other than a natural
person means:

a. The full name of the entity, the type of entity (e.g., corporation, partnership,
etc.), the address of itsprincipal place of business, its principal business
activity and, if it is a corporation, the jurisdiction under the laws of which it
has been organized and the date of such organization.

b. Each of the entity’s officers, directors, shareholders, or other principals.

c. Any other available information concerning the existence or identity of the
entity.
8. The term “property” or “subject property” refers to the properties located at 22-227, 231-
237, 241-247, 251-257, 261-267 NE 141 Street and 14110-14116, 14120-14126, 14200-14206,
14210-14216, 14220-14226 and 14230-14236 NE 3 Court, Miami, FL 33161 as covered under the
subject Policy of Insurance.

9. The term “loss” or “claim” refers to the loss described in the Complaint or the loss
reported to AMERICAN COASTAL INSURANCE COMPANY for a date of loss occurring on or
about November 8, 2020, related to Tropical Storm Eta.

INSTRUCTIONS

Before answering the following Interrogatories, will you please make such inquiries of
your agents, servants, employees and/or attorneys as will enable you to make full and true answers
to the following, in accordance with the applicable Florida Rules of Civil Procedure. Additionally,
if more space is required, please use a separate sheet of paper and attach same behind the sheet
where the respective question appears.
INTERROGATORIES TO PLAINTIFF

1. State the name, address, and title of the person answering these Interrogatories on behalf
of ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC.

2. Describe, in detail:

(a) How and when the loss was discovered? In responding to this request, please
include the time of day you discovered the loss. In the event you did not
personally discover the loss, please identify the individual who first discovered
the loss.

(b) Specifically, what damage did you observe relating to the loss? In responding
to this request, please identify all areas of property that you observed were
damaged, including water damage resulting from the loss; this request does not
seek amounts or line items contained in a property damage estimate prepared
for your loss but seeks personal observations of property damaged areas.
3. Identify all individuals and/or companies who inspected or evaluated the property,
including but not limited to public adjusters, roofers, engineers, general contractors, or any other
expert or tradesman who inspected the property at any time after the date of loss for this claim. In
responding to this request, identify the individual/company who inspected the property, the date
of inspection, and whether a report was written relating to the inspection. In addition, identify the
date you first contacted these individuals/companies and the date they were retained.

4. State, in detail, all repairs performed to the Premises relating to the loss. In
responding to this request, identify all persons or entities that have performed repairs in any way
to the property that is the subject of this claim, including the date of repairs, the type of repairs,
the costs of repairs, all municipal or county building permits obtained for repairs, including dates
of application, for any repairs to any other area of the residence you claimed was damaged as a
result of your loss as described in the Complaint.
5. When did you first discover damage to the Premises? In responding to this
Interrogatory, please describe when the damage was first observed on each building that makes
up the Premises.

6. What damages did you observe on the Premises? In responding to this
Interrogatory, please describe the damages observed on each building that makes up the Premises.

7. When did you first discover the roof damages to the Premises? In responding to
this Interrogatory, please describe when the roof damages were first observed on each building
that makes up the Premises.

8. What roof damages did you observe on the Premises? In responding to this
Interrogatory, please describe the roof damages observed on each building that makes up the
Premises.
9. Please state the amount of damages being sought in this lawsuit under the subject
Policy.

10. State all areas of the Premises that have been renovated or remodeled five years
prior to the date of loss of September 10, 2017. In responding to this request, please include the
corresponding dates of the renovations/remodeling; the company or persons that performed or
are performing the renovations/remodeling; and the amount paid for each area of the property
that was renovated/remodeled.
11. State all areas of the Premises that have been renovated or remodeled or are in the
process of being renovated or remodeled as of the date of loss of September 10, 2017. In
responding to this request, please include the corresponding dates of the renovations/remodeling;
the company or persons that performed or are performing the renovations/remodeling; and the
amount paid for each area of the property that was renovated/remodeled.

12. List the names and addresses of all persons who are believed or known by you, your
agents, or your attorneys to have any knowledge concerning any of the issues in this lawsuit and
specify the subject matter about which the witness has knowledge.

13. Describe, in detail, any and all actions to protect the subject property and/or
mitigate the damages claimed in the loss. This includes any mitigation companies that were
retained.
14. When was the roof of the Premises last replaced? In responding to this request,
identify the individual or company that performed the installation of the roof of the Premises,
either as a whole or a particular building within the Premises; the date the roof was completed,
and the amount you paid/charged for the roof replacement.

15. State all areas of the Premises that have had any repairs performed five years prior
to the date of loss of November 9, 2020. In responding to this request, please include the
corresponding dates of the repairs; the company or persons that performed the repairs; and the
amount paid for each area of the property that was repaired.

16. Identify any and all Board Members of ARBOUR TOWNHOUSE CONDOMINIUM
ASSOCIATION, INC., from the date of the loss until the present.
17. Which damage to the premises are you claiming is a result of this loss? In
responding to this request, please identify all areas of property that you, the Association, or your
representatives, are claiming were damaged as a result of this loss. This request does not seek
amounts or line items contained in a property damage estimate prepared for your loss but seeks
specific damages that you are seeking to recover for.

18. Identify all property management companies and/or maintenance companies
retained by the Association from five years prior to the date of loss until current day.
19. State and describe the process of how any and all incident reports are generated,
received, maintained and stored for the premises. In doing so, please state how long incident
reports are kept and if there are any specific programs used to store them. Please identify if any
outside companies were retained to handle intake of any incident reports. Please identify, whether
physically or electronically, where these incident reports are stored.

20. Are you aware of any roof leaks at the property within five years prior to the date
of loss? If so, describe how this information was learned, how this information is stored, which
units were effected and if any repairs were made.
21. State all dates the Association Board has convened from five years prior to the date
of loss until the current day. In doing so, please identify the meeting minutes that were kept for the
Association Board meetings and how/where these meeting minutes are currently stored. This
includes all annual meetings as well.

22. Identify all unit owners of the premises on the date of loss. This interrogatory
specifically seeks the name and contact information of any individual and/or corporation who
owned a unit at the premises at the time of loss.

23. State and describe the process of how any and all complaints by unit owners and/or
tenants are received, maintained and stored for the premises. In doing so, please state how long
complaints by unit owners and/or tenants are kept and if there are any specific programs used to
store them. Please identify if any outside companies were retained to handle intake of any
complaints by unit owners and/or tenants. Please identify, whether physically or electronically,
where these complaints by unit owners and/or tenants are stored.
24. State all repairs, upgrades, replacements or renovations that have been made to any
part of the roofing systems at the premises in relation to a Hurricane Irma property claim with a
date of loss in September 10, 2017.

25. Within five years prior to the date of loss, has ARBOUR TOWNHOUSE
CONDOMINIUM ASSOCIATION, INC., received any complaints or been made aware of
damages, by any unit owners and/or tenants of the premises, for any areas of the premises in which
damage is being claimed for this loss? If yes, please identify when the complaint was received,
who made the complaint and the contents of the complaint made.
26. Identify all claims made within the last five years to any insurance company. Please
include the claim number, date of loss, insurance company and whether any payment was received.

27. Identify all interior damages being claimed as a result of this loss. Specifically,
identify which units were affected, the specific damages being claimed as a result of this loss and
when each of the damages were first noticed.

28. Identify all correspondence and documents sent to American Coastal from you
and/or your representatives from the date this claim was reported until current. Please identify the
date the correspondence/documents were sent, the method they were sent and who specifically
sent them.

29. Has the Association, or any of its representatives, executed an Assignment of
Benefits for any portion of this claim? If so, list who such assignment was executed with and
which portion of the claim was assigned.
I have read the foregoing Answers to Interrogatories and do swear that they are true.

_____________________________________
Authorized Agent for ARBOUR TOWNHOUSE
CONDOMINIUM ASSOCIATION, INC.

Print Name: ______________________________

Title: ____________________________________

STATE OF FLORIDA :
: ss
COUNTY OF _________________ :

The foregoing instrument was acknowledged before me this _____ day of

____________________, 2021, by ______________________ as ________________ for

ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC., who is personally known

to me or who has produced ____________________________ as identification.

My commission expires:

Signature of Acknowledger

Typed/Printed Name of Acknowledger
Filing # 137218553 E-Filed 10/25/2021 04:00:56 PM

IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA

Case No.: 2021-015633-CA-01

ARBOUR TOWNHOUSE CONDOMINIUM
ASSOCIATION, INC.,

Plaintiff,

AMERICAN COASTAL INSURANCE
COMPANY,

Defendant.
____________________________________/

DEFENDANT’S FIRST REQUEST FOR PRODUCTION TO PLAINTIFF

Defendant, AMERICAN COASTAL INSURANCE COMPANY, requests Plaintiff,

ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC., to produce the original or

best copy of the items listed herein below at the offices of the Defendant’s undersigned counsel

for inspection and/or copying within the time period prescribed by law:

DEFINITIONS

1. The term "documents" means and includes, without limitation, all writings of any
kind, including the originals and all non-identical copies or drafts, whether printed, recorded,
stored, or reproduced by any mechanical or electronic process or written or produced by hand,
including computer tapes (and backup tapes), whether different from the original by reason of any
notation made on such copy or draft or otherwise including, without limitation, correspondence,
memoranda, notes, diaries, statistics, letters, e-mail, electronic computer files, telegrams, minutes,
contracts, reports, accident reports, incident reports, studies, calculations, computations, surveys,
checks, statements, receipts, returns, summaries, pamphlets, books, prospectuses, circulars, trade
letters, advertisements, interoffice communications, offers, notations of any sort of
conversation(s), telephone calls, meetings or other communications, bulletins, printed matter,
computer print-outs, teletypes, facsimiles, invoices, work sheets and all drafts, alterations,
modifications, changes, and amendments of any of the foregoing, graphic or aural writs, records
or representations of any kind including, without limitation, photographs, charts, graphs,
microfiche, microfilm, videotape, recordings, motion pictures; and electronic, mechanical or
electric records or representations of any kind including, without limitation, tapes, cassettes and
disc recordings, and writings and printed material of every kind, whether or not the document is
out of your possession, custody or control.

2. The term "correspondence" means any tangible object that conveys information or
memorializes information that was conveyed in tangible or oral form including, but not limited to,
writings, letters, memoranda, electronic mail (otherwise known as “e-mail”), facsimiles, reports,
notes, telegrams and interoffice communication.

3. The term "relating to" as used herein is defined to mean evidencing, referring to,
pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected
with the matters discussed.

4. The term “properties” or “subject properties” refers to the Insured properties located at
22-227, 231-237, 241-247, 251-257, 261-267 NE 141 Street and 14110-14116, 14120-14126,
14200-14206, 14210-14216, 14220-14226 and 14230-14236 NE 3 Court, Miami, FL 33161as
covered under the subject Policy of Insurance.

5. The term “you” or “your” refers to Plaintiff, ARBOUR TOWNHOUSE CONDOMINIUM
ASSOCIATION, INC., and/or Plaintiff’s designated agent.

6. The term “loss” or “this claim” refers to the loss described in the Complaint or the
loss reported to American Coastal Insurance Company for a date of loss occurring on or about
November 8, 2020.

DOCUMENTS REQUESTED

1. All documents, including, but not limited to, correspondence between yourself or
any agent of yours and American Coastal Insurance Company and/or its agents from the time of
reporting of the loss to the present.

2. All documents evidencing agreements for representation between yourself and any
individual or business entity representing you in this claim, including but not limited to contracts,
letters of representation, correspondence, and fee schedules for representation. This request does
not seek agreements for legal representation, but does seek unredacted documents responsive to
this request.

3. Any and all documents evidencing any assignments of benefits you conveyed to
any third-parties for any services rendered at the properties in relation to the subject loss.

4. Any and all documents, correspondence, and/or invoices relating to the loss until
present.
5. All documents, invoices, correspondence, and/or proof of payment(s) to any
vendors, relating to the loss.

6. All Assignment of Benefits executed in this matter.

7. All documents evidencing the damages that you are claiming in this lawsuit,
including, but not limited to photographs, estimates, contracts, receipts, statements, invoices, and
work orders.

8. All documents evidencing payment to any third-party for services relating to the
loss.

9. Any proof of loss statements from you relating to the claim.

10. All documents evidencing the replacement of damaged property as a result of the
loss, including but not limited to contracts, receipts, canceled checks, bills of sale, statements,
ATM receipts, credit card statements, and invoices.

11. All documents evidencing all repairs to any area of the properties that are being
claimed in your loss.

12. All photographs, videos, recordings, film, diagrams, drawings, charts, sketches or
any other documents illustrating the damages sustained in the loss.

13. All photographs, videos, recordings, film, diagrams, drawings, charts, sketches or
any other documents illustrating the cause of any and all damages associated with the loss.

14. All engineer, roofer or expert reports in support of the subject claim, including but
not limited to and photographs taken by the engineer, roofer, or expert.

15. All documents evidencing roofing repairs or service calls to a roofer or roofing
company, including but not limited to work orders, invoices, statements, inspections, payments,
estimates, and receipts, from November 8, 2020 to present.

16. All documents evidencing roofing repairs or service calls to a roofer or roofing
company, including but not limited to work orders, invoices, statements, inspections, payments,
estimates, and receipts, before November 8, 2020.

17. All documents prepared by third parties who inspected or evaluated the properties
relating to the loss.

18. All documents relating to purchase, rental or installation of a roof tarpaulin after
the date of loss.

19. All documents relating to repairs performed on the interior of the premises from
five years prior to the date of loss until present.
20. All documents evidencing estimates, work orders, invoices, statements, and
receipts relating to the repair or replacement of the roof of the Premises.

21. All documents evidencing renovations or remodeling to the property from
November 8, 2020 through present. In responding to this request, please provide all estimates,
statements, invoices, bills, receipts, credit card statements, and cancelled checks that document the
renovations or remodeling of the property.

22. All documents in your possession evidencing communications with your Public
Adjuster and/or Loss Consultant.

23. Any meeting minutes from five (5) years prior to the loss and from the date of loss
until today.

24. Any maintenance records related to the roof, windows, or any interior leaks at the
subject property from five (5) years prior to the loss and from the date of loss until today.

25. Any and all incident reports, maintenance requests, work orders, etc., related to
property damage at the subject properties within five (5) years prior to the reported date of loss.
This includes all records for prior roof repairs, interior repairs, window repairs, etc.

26. Any by-laws, rule and procedures, declarations or association documents in place
at the time of the loss evidencing the responsibilities of the association and unit owners.

27. All documents evidencing your efforts to protect the property from further damage.

28. All documents relating to any prior insurance claims at the property, including, but
not limited to, any repair receipts, estimates, photographs, invoices, etc.

29. All documents in your possession relating to the loss.

30. All documents related to a Hurricane Irma claim made on behalf of the property
with a date of loss of September 17, 2017. This includes documents submitted to the Insurer,
evidence of any coverage extended under the Policy, documents of repairs made after the loss and
proof of payments made for repairs.
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 25th day of October, 2021, this document was filed

using the Florida Courts E-Filing Portal. This document is being served on all counsel and pro se

parties of record by the Florida Courts E-Filing Portal, pursuant to and in compliance with Fla.

R. Jud. Admin. 2.516. The mailing and electronic addresses are: Amy E. Ruiz, Esquire, Taylor

Espino Vega & Touron, P.A., FTouron@TEVTLaw.com; ARuiz@TEVTLaw.com;

SGuerrero@TEVTLaw.com; TEVTservice@gmail.com, 201 Alhambra Circle, Suite 801, Coral

Gables, FL 33134, (305) 443-2043/(305) 443-2048 (F), Attorney for Plaintiff, ARBOUR

TOWNHOUSE CONDOMINIUM ASSOCIATION, INC.

KELLEY KRONENBERG

/s/ Jeremy M. Mishali
Jeremy M. Mishali, Esq.
Fla. Bar No.: 106115
jmishali@kelleykronenberg.com
Jeffrey M. Wank, Esq.
Fla. Bar No.: 68010
jwank@kelleykronenberg.com
10360 West State Road 84
Fort Lauderdale, FL 33324
Telephone: (954) 370-9970
Facsimile: (954) 382-1988
Attorneys for American Coastal Insurance
Company
Address for service of pleadings only:
jwank@kelleykronenberg.com
jmishali@kelleykronenberg.com
glamchick@kelleykronenberg.com
Filing # 140263503 E-Filed 12/13/2021 02:43:15 PM
EXHIBIT "B"
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL
CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: 2021-015633-CA-01
SECTION: CA08
JUDGE: Lourdes Simon

Arbour Townhouse Condominium Association, Inc
Plaintiff(s)

vs.

American Coastal Insurance Company
Defendant(s)
____________________________/

AGREED ORDER ON PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO DEFENDANT’S FIRST SET OF DISCOVERY

THIS CAUSE having come on to be heard on the Plaintiff’s Motion for Extension of

Time to Respond to Defendant’s First Set of Discovery, the Court being advised of agreement of

counsel for the parties and being otherwise fully advised in the premises, it is hereby

ORDERED that:

1. The Plaintiff’s Motion for Extension of Time to Respond to Defendant’s First Set of

Discovery is hereby GRANTED.

2. Plaintiff shall file its responses to Defendant’s First Request for Production and

First Set of Interrogatories on or before January 10, 2022.

Case No: 2021-015633-CA-01 Page 1 of 2
DONE and ORDERED in Chambers at Miami-Dade County, Florida on this 13th day of
December, 2021.

2021-015633-CA-01 12-13-2021 2:32 PM
Hon. Lourdes Simon

CIRCUIT COURT JUDGE
Electronically Signed

No Further Judicial Action Required on THIS MOTION

CLERK TO RECLOSE CASE IF POST JUDGMENT

Electronically Served:
Amy E. Ruiz, ARuiz@RuizGetmanLaw.com
Amy E. Ruiz, SGuerrero@RuizGetmanLaw.com
Francisco Touron III, Frank@TouronLaw.com
Jeffrey Wank, jwank@kelleykronenberg.com
Jeffrey Wank, salexis@kelleykronenberg.com
Jeremy M. Mishali, jmishali@kelleykronenberg.com
Jeremy M. Mishali, glamchick@kelleykronenberg.com
Steven J. Getman, SGetman@RuizGetmanLaw.com

Physically Served:

Case No: 2021-015633-CA-01 Page 2 of 2

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Case No.

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Document Filed Date

February 24, 2022

Case Filing Date

June 30, 2021

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Motion,Ex Parte: ARBOUR TOWNHOUSE CONDOMINIUM ASSOCIATION, INC VS AMERICAN COASTAL INSURANCE COMPANY

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