On May 17, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Lopez, Belinda,
Lopez, Luis,
and
United Property & Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Collier County.
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Filing # 92504668 E-Filed 07/12/2019 05:17:01 PM
IN THE CIRCUIT COURT OF THE 20TH
JUDICIAL CIRCUIT IN AND FOR INDIAN
COLLIER COUNTY, FLORIDA
CASE NO. 11-2019-CA-0020080001XX
BELINDA LOPEZ AND LUIS LOPEZ,
Plaintiff,
v.
UNITED PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
/
UNITED PROPERTY AND CASUALTY INSURANCE COMPANY’S
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ FIRST
REQUEST FOR ADMISSIONS, FIRST REQUEST FOR PRODUCTION AND FIRST
SET OF INTERROGATORIES
Defendant, United Property and Casualty Insurance Company (“UPC”), by and through
undersigned counsel, hereby files this motion for an extension of time of 30 days to respond to
Plaintiffs’ First Request for Admissions, First Request for Production and First Set of Interrogatories
(the “Discovery”), and states as follows:
1. Plaintiffs served on UPC the Complaint and Discovery on May 29, 2019.
2. UPC’s response to the Discovery comes due on July 15, 2019.
4. The undersigned is in the process of reviewing materials regarding this matter in
order to address Plaintiffs’ claim, and seeks an additional 30 days from July 15, 2019 (up to and
including August 14, 2019) to respond to Plaintiffs’ Discovery.
4. UPC states that this request is made in good faith and not for purposes of delay, and
that no party will be prejudiced by the granting thereof.
WHEREFORE, UPC respectfully requests an extension of time of 30 days up to and
including August 14, 2019 to respond to Plaintiffs’ Discovery.
4849-6808-6172.1 1
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/12/2019 05:17:01 PMRespectfully submitted,
LEWIS BRISBOIS BISGAARD & SMITH LLP
110 SE 6th Street, Suite 2600
Fort Lauderdale, Florida 33301
Telephone: 954.728.1280
Facsimile: 954.728.1282
By:_/4/ Daniel B, Allison
BRADLEY S. FISCHER, ESQ.
Florida Bar No. 716553
bradley.fischer@lewisbrisbois.com
DANIEL B. ALLISON, ESQ.
Florida Bar No. 115095
daniel.allison@lewisbrisbois.com
Counsel for United Property & Casualty Ins. Co.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that on July12, 2019, a copy of the foregoing was electronically filed
with the Court and service of the same was made to counsel on the Service List below in accordance
with Florida Supreme Court Administrative Order AOSC13-49.
/s/ Daniel B. Allison
DANIEL B. ALLISON, ESQ.
Florida Bar No. 115095
SERVICE LIST
Christopher Ligman, Esq.
Christopher Ligman, P.A.
1342 Colonial Boulevard
Suite C-22
Fort Myers, Florida 33907
Telephone: (239) 985-9805
Email: chrisligman@DelayedClaims.com
eservice@DelaynedClaims.com
4849-6808-6172.1 2
Case Filing Date
May 17, 2019
Category
Contract and Indebtedness
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Filing # 92504668 E-Filed 07/12/2019 05:17:01 PM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR INDIAN COLLIER COUNTY, FLORIDA CASE NO. 11-2019-CA-0020080001XX BELINDA LOPEZ AND LUIS LOPEZ, Plaintiff, v. UNITED PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / UNITED PROPERTY AND CASUALTY INSURANCE COMPANY’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ FIRST REQUEST FOR ADMISSIONS, FIRST REQUEST FOR PRODUCTION AND FIRST SET OF INTERROGATORIES Defendant, United Property and Casualty Insurance Company (“UPC”), by and through undersigned counsel, hereby files this motion for an extension of time of 30 days to respond to Plaintiffs’ First Request for Admissions, First Request for Production and First Set of Interrogatories (the “Discovery”), and states as follows: 1. Plaintiffs served on UPC the Complaint and Discovery on May 29, 2019. 2. UPC’s response to the Discovery comes due on July 15, 2019. 4. The undersigned is in the process of reviewing materials regarding this matter in order to address Plaintiffs’ claim, and seeks an additional 30 days from July 15, 2019 (up to and including August 14, 2019) to respond to Plaintiffs’ Discovery. 4. UPC states that this request is made in good faith and not for purposes of delay, and that no party will be prejudiced by the granting thereof. WHEREFORE, UPC respectfully requests an extension of time of 30 days up to and including August 14, 2019 to respond to Plaintiffs’ Discovery. 4849-6808-6172.1 1 FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 07/12/2019 05:17:01 PMRespectfully submitted, LEWIS BRISBOIS BISGAARD & SMITH LLP 110 SE 6th Street, Suite 2600 Fort Lauderdale, Florida 33301 Telephone: 954.728.1280 Facsimile: 954.728.1282 By:_/4/ Daniel B, Allison BRADLEY S. FISCHER, ESQ. Florida Bar No. 716553 bradley.fischer@lewisbrisbois.com DANIEL B. ALLISON, ESQ. Florida Bar No. 115095 daniel.allison@lewisbrisbois.com Counsel for United Property & Casualty Ins. Co. CERTIFICATE OF SERVICE THEREBY CERTIFY that on July12, 2019, a copy of the foregoing was electronically filed with the Court and service of the same was made to counsel on the Service List below in accordance with Florida Supreme Court Administrative Order AOSC13-49. /s/ Daniel B. Allison DANIEL B. ALLISON, ESQ. Florida Bar No. 115095 SERVICE LIST Christopher Ligman, Esq. Christopher Ligman, P.A. 1342 Colonial Boulevard Suite C-22 Fort Myers, Florida 33907 Telephone: (239) 985-9805 Email: chrisligman@DelayedClaims.com eservice@DelaynedClaims.com 4849-6808-6172.1 2