Motion,Ex Parte: Veronica Tomor, et al Plaintiff vs. Universal Property And Casualty Insurance Company Defendant

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                                Filing# 179680589 E-Filed 08/15/2023 12:44:03                    PM

                                                                       IN   THE COUNTY COURT OF THE                 17TH
                                                                       JUDICIAL      CIRCUIT      IN      AND FOR
                                                                       BROWARD COUNTY, FLORIDA

        DRI-MAX RESTORATION, LLC.                                      CASE NO.: CACE-21-010647
        A/A/O VERONICA TOMOR & FRED
        GAROFALO,

                          Plaintiff,


        V

        UNIVERSAL PROPERTY & CASUALTY
        INSURANCE COMPANY,

                          Defendant.

                                                                  i



                         PLAINTIFF'SMOTION FOR EXTENSION OF TIME TO FILE
                           RESPONSE TO DEFENDANT'S DISCOVERY REQUESTS

                 COMES NOW,            Plaintiffs,BELIZARDIZ          RODRIGUEZ AND KRISTINE COBAIN-

        RODRIGUEZ,         and hereby moves          this   Court for an order extending the time to respond to


        Defendant's,     PEOPLE'S TRUST INSURANCE COMPANY, discoveryrequests, and                           in support


        thereof,states as follows:

                 1.       On    or about July    13th,2023;     Plaintiff   was served with Defendant's discovery

        requests.


                 2.       Due   to   scheduling conflicts of the Plaintiff and the undersigned, the undersigned

        seeks an additional thirty(30)days in which to adequatelyrespond to Defendant's Interrogatories


        and Request for Production to        Plaintiff.



                 3        Plaintiff is not   seeking to extend any other deadlines.

                 4.       An extension of time for the requesteddeadline will be        sufficient to   adequatelyfile

                                              and Request for Production to Plaintiff.
        responses to Defendant's Interrogatories




            *** FILED:   BROWARD COUNTY,        FL   BRENDA D. FORMAN, CLERK 08/15/2023        12:44:03   PM.****
       5.          This Motion    is   not made for the purpose ofunduly delay and Defendant will not be


prejudiceby the grantingof this Motion.

       6.          Plaintiff reserves their   rightto objectto any and      all   discovery.


       WHEREFORE,                Plaintiffs,DRI-MAX        RESTORATION, LLC. A/A/O VERONICA

TOMOR & FRED GAROFALO,                      respectfully
                                                       requests     this    Honorable Court enter an Order


granting    this   Motion   to   Extend the time in which to         file    their responses to   Defendant's


UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY,                                        discoveryrequests and

grant such other and as this Court        deems justand proper.




                                        CERTIFICATE OF SERVICE
       I    HEREBY CERTIFY              that a true   and correct copy of the foregoing was served via

Electronic Mail to: counsel of record for the Defendant, on          this.12day of August 2023.
                                                      Your Insurance Attorney, PLLC.
                                                      2601 South Bayshore Drive 18th Floor
                                                      Coconut Grove, FL 33133
                                                      Phone No.: 1-888-570-5677
                                                      Fax: 1-888-745-5677
                                                      Email:YIA7@Yourinsuranceattomey.com
                                                      By--/sl   Samantha 92 79006, Esq.
                                                          Samantha R. Wood, Esq.
                                                          Florida Bar No. 1003177