On April 09, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Garces, Elena,
Garces, Jairo,
and
Citizens Property Insurance Corporation,
for 3
in the District Court of Broward County.
Preview
Filing# 160425243 E-Filed 11/01/2022 05:20:13 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
JAIRO GARCES AND
ELENA GARCES,
Plaintiffs,
V CASE NO.: CACE-21-007270
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
i
DEFENDANT'S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF'S EXPERT DISCOVERY
COMES NOW, Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, by and through undersigned counsel, respectfullyrequests this Court to enter
an order grantingan extension of time to respond to Plaintiff's Expert Discovery,and in support
thereof states as follows:
1. Plaintiff filed its Expert Request for Production and Expert Interrogatories
to
Defendant.
2. Defendant requiresadditional time to form a responsivepleadingto Plaintiff' s
Expert Discovery.
3 Defendant respectfully
requests this Court grants an extension of time to respond
to said Discovery.
4. This Motion is not meant to harass or prejudicePlaintiff in any way, nor is it filed
for the purpose of undue hindrance or delay.
WHEREFORE, Respondent respectfullyrequests that this Honorable Court enter an
order grantingDefendant an extension o f time to respond to Plaintiff' s Expert Discovery.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/01/2022 05:20:12 PM.****
CASE NO.: CACE-21-007270
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been provided
via electronic correspondence to: Kimberly Innocent, Esq. at Kimberly@innocentlawfirm.com,
st
on this 1
s
day ofNovember, 2022.
Respectfully submitted,
RUBINTON SIMMS, P.A.
3440 Hollywood Blvd, Suite 460
Hollywood, Florida 33021
Telephone: 954-251-5500
Fax: 954-251-5501
By: /s/
/PceCaatd/W
JEFFREY A. RUBINTON, ESQ.
Florida Ban 821756
JOSE CASTELLO, ESQ.
Florida Ban 1006406
Primary E-Mail: JCastello@rubintonlaw.com
Secondary E-Mail: eservice@rubintonlaw.com
2
Document Filed Date
November 01, 2022
Case Filing Date
April 09, 2021
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