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Filing # 174854560 E-Filed 06/07/2023 11:26:35 PM
IN THE CIRCUIT COURT OF THE 207
JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
AURIANA LAUTURE,
CASE NO.: 23CA001791
Plaintiff,
vs.
EDISON INSURANCE COMPANY,
Defendant.
/
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW, the Defendant EDISON INSURANCE COMPANY (“Edison”), by and
through the undersigned counsel, pursuant to the applicable Fla. R. Civ. P., to hereby file this
Motion for Extension of Time to Respond to Plaintiff's Complaint, and in support thereof states
as follows:
1 The Complaint in this matter was served upon FPIC on May 18, 2023, and a
response to the same is due by June 7, 2023.
2. Undersigned counsel is in need of additional time within which to prepare a
response to the Complaint.
3 Accordingly, the undersigned counsel respectfully requests that this Court grant
this Motion and provide the undersigned counsel with additional time to respond to the
Complaint.
4 This is Edison’s first formal request for an extension to respond to Plaintiffs
Complaint. Said request is made in good faith and is not intended to delay action on this matter.
5 The requested extension will not prejudice any party in this matter.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-116
6 The undersigned will confer with counsel for the Plaintiff prior to the date this
Motion is heard in an effort to reach an agreement to the extension.
WHEREFORE, EDISON INSURANCE COMPANY, respectfully requests that this
Court to enter an Order granting this motion and granting any further relief this Court deems just
and proper under the circumstances.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that pursuant to Florida Rule of Judicial Administration 2.516,
a true and correct copy of the foregoing was sent by E-Mail to: Otto E. Berges, Esq., Alliance
Law Firm, 1665 Palm Beach Lakes Blvd., Suite 1001, West Palm Beach, FL 33401,
oberges@alliancelawfirm.com, jbendel@alliancelawfirm.com, eservice@alliancelawfirm.com,
on this 7" day of June, 2023.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A.
Attorneys for Defendant
9300 South Dadeland Boulevard
Fourth Floor
Miami, Florida 33156
Telephone: (305) 670-1101
Facsimile: (305) 670-1161
By: /s/ SANDRA RODRIGUEZ
SANDRA RODRIGUEZ, ESQUIRE
Florida Bar No.: 121661
sandra.rodriguez@qpwblaw.com
DANIEL TAMAROFF, ESQUIRE
Florida Bar No.: 92083
daniel.tamaroff@qpwblaw.com
JOSE E. BOSCH, ESQUIRE
Florida Bar No.: 542431
jbosch@qpwhblaw.com
For service of court documents only:
Designated Primary Email:
srodriguez.pleadings@qpwblaw.com
Designated Secondary Emails:
jbosch.pleadings@qpwblaw.com
dtamaroff.pleadings@qpwblaw.com
2.
QUINTAIROS, PRIETO, WooD & BOYER, P.A., ATTORNEYS AT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-1161
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Filing # 174854560 E-Filed 06/07/2023 11:26:35 PM IN THE CIRCUIT COURT OF THE 207 JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION AURIANA LAUTURE, CASE NO.: 23CA001791 Plaintiff, vs. EDISON INSURANCE COMPANY, Defendant. / MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW, the Defendant EDISON INSURANCE COMPANY (“Edison”), by and through the undersigned counsel, pursuant to the applicable Fla. R. Civ. P., to hereby file this Motion for Extension of Time to Respond to Plaintiff's Complaint, and in support thereof states as follows: 1 The Complaint in this matter was served upon FPIC on May 18, 2023, and a response to the same is due by June 7, 2023. 2. Undersigned counsel is in need of additional time within which to prepare a response to the Complaint. 3 Accordingly, the undersigned counsel respectfully requests that this Court grant this Motion and provide the undersigned counsel with additional time to respond to the Complaint. 4 This is Edison’s first formal request for an extension to respond to Plaintiffs Complaint. Said request is made in good faith and is not intended to delay action on this matter. 5 The requested extension will not prejudice any party in this matter. QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-116 6 The undersigned will confer with counsel for the Plaintiff prior to the date this Motion is heard in an effort to reach an agreement to the extension. WHEREFORE, EDISON INSURANCE COMPANY, respectfully requests that this Court to enter an Order granting this motion and granting any further relief this Court deems just and proper under the circumstances. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that pursuant to Florida Rule of Judicial Administration 2.516, a true and correct copy of the foregoing was sent by E-Mail to: Otto E. Berges, Esq., Alliance Law Firm, 1665 Palm Beach Lakes Blvd., Suite 1001, West Palm Beach, FL 33401, oberges@alliancelawfirm.com, jbendel@alliancelawfirm.com, eservice@alliancelawfirm.com, on this 7" day of June, 2023. QUINTAIROS, PRIETO, WOOD & BOYER, P.A. Attorneys for Defendant 9300 South Dadeland Boulevard Fourth Floor Miami, Florida 33156 Telephone: (305) 670-1101 Facsimile: (305) 670-1161 By: /s/ SANDRA RODRIGUEZ SANDRA RODRIGUEZ, ESQUIRE Florida Bar No.: 121661 sandra.rodriguez@qpwblaw.com DANIEL TAMAROFF, ESQUIRE Florida Bar No.: 92083 daniel.tamaroff@qpwblaw.com JOSE E. BOSCH, ESQUIRE Florida Bar No.: 542431 jbosch@qpwhblaw.com For service of court documents only: Designated Primary Email: srodriguez.pleadings@qpwblaw.com Designated Secondary Emails: jbosch.pleadings@qpwblaw.com dtamaroff.pleadings@qpwblaw.com 2. QUINTAIROS, PRIETO, WooD & BOYER, P.A., ATTORNEYS AT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-1161