On October 15, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Gabriel , Irene,
and
Universal Property & Casualty Insurance Company,
for 3
in the District Court of Broward County.
Preview
Filing # 105247794 E-Filed 03/20/2020 06:12:31 PM
IN THE CIRCUIT COURT OF THE 17'%
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
IRENE GABRIEL CASE NO.: CACE-19-021327
Plaintiff,
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT.
Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY
(“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plaintiff's Complaint and states as follows:
1 This matter arises out of a claim asserted by IRENE GABRIEL (“Plaintiff”) against
Universal for alleged water damages suffered on September 10, 2017.
The undersigned counsel is in receipt of Plaintiff's Complaint; however, additional time is
necessary to respond and as such, Universal would respectfully request additional time to
review the file and file a response to Plaintiff's Complaint.
Universal requests an additional thirty days to file a response to Plaintiff's Complaint, up
to and including April 17, 2020.
This Motion is not being filed for the purposes of delay and will not prejudice any party.
WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests
this Court to enter an Order granting Defendant additional time to respond to Plaintiff's Complaint.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/20/2020 06:12:31 PM.**#*
Irene Gabriel vs. UPCIC
CASE NO.: CACE-19-021327
Page 2 of 2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Angelia Baldwin Purnell, Esq., The Purnell Law Firm, P.A., ( urnell urnell-
law.com) on the 20" day of March 2020.
Attorney for Defendant
Universal Property & Casualty Ins. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges only)
Facsimile: 954-958-1262
By:_/s/ John Rodriguez
Verhonda Williams-Darrell, Esq.
Florida Bar No. 92607
John Rodriguez, Esq.
Florida Bar No. 67268
For Service of Court Documents only:
Primary: upciceservice02@universalproperty.com
Secondary: mm0107@universalproperty.com
Tertiary: vw1210@universalproperty.com
For Scheduling Matters:
mm0107@universalproperty.com
*Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com
or upciceservice02@universalproper com.
Document Filed Date
March 20, 2020
Case Filing Date
October 15, 2019
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Filing # 105247794 E-Filed 03/20/2020 06:12:31 PM IN THE CIRCUIT COURT OF THE 17'% JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA IRENE GABRIEL CASE NO.: CACE-19-021327 Plaintiff, vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT. Defendant, UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY (“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plaintiff's Complaint and states as follows: 1 This matter arises out of a claim asserted by IRENE GABRIEL (“Plaintiff”) against Universal for alleged water damages suffered on September 10, 2017. The undersigned counsel is in receipt of Plaintiff's Complaint; however, additional time is necessary to respond and as such, Universal would respectfully request additional time to review the file and file a response to Plaintiff's Complaint. Universal requests an additional thirty days to file a response to Plaintiff's Complaint, up to and including April 17, 2020. This Motion is not being filed for the purposes of delay and will not prejudice any party. WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests this Court to enter an Order granting Defendant additional time to respond to Plaintiff's Complaint. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/20/2020 06:12:31 PM.**#* Irene Gabriel vs. UPCIC CASE NO.: CACE-19-021327 Page 2 of 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Angelia Baldwin Purnell, Esq., The Purnell Law Firm, P.A., ( urnell urnell- law.com) on the 20" day of March 2020. Attorney for Defendant Universal Property & Casualty Ins. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges only) Facsimile: 954-958-1262 By:_/s/ John Rodriguez Verhonda Williams-Darrell, Esq. Florida Bar No. 92607 John Rodriguez, Esq. Florida Bar No. 67268 For Service of Court Documents only: Primary: upciceservice02@universalproperty.com Secondary: mm0107@universalproperty.com Tertiary: vw1210@universalproperty.com For Scheduling Matters: mm0107@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice02@universalproper com.