On August 31, 2021 a
Motion for Extension of Time
was filed
involving a dispute between
Cannis, Jerry,
Cannis, Peggy,
and
Universal Property And Casualty Insurance Company,
for 3
in the District Court of Broward County.
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Filing# 159921779 E-Filed 10/25/2022 01:21:29 PM
IN THE CIRCUITCOURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JERRY CANNIS AND CASE NO.: CACE-21-016611 (09)
PEGGY CANNIS,
Plaintiff,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY.
Defendant.
'
PLAINTIFFS' FIRST MOTION FOR EXTENSION OF TIME TO FILE RESPONSES
TO DEFENDANT'S EXPERT DISCOVERY REQUESTS
JERRY
Plaintiffs, CANNIS AND PEGGY CANNIS, by and through the undersigned
counsel, hereby file this Motion requestingadditional time to respond to Defendant's Expert
Discovery Requests, and in support thereof,state as follows:
1. On ,rd
or about September 231 ',2022; Plaintiffs were served with Defendant's Expert
Discovery Requests.
2. Plaintiffs are in need of additional time to respond to Defendant's Discovery
Requests and hereby respectfully
request an additional twenty (20) days to submit their responses
to same.
3 The requestedextension sought herein will allow sufficient time for Plaintiffs to
adequatelyrespond to Defendant's Expert Discovery Requests.
4. By filingthis Motion for Extension of Time, Plaintiffs hereby reserve the rightto
assert any and all objectionsto Defendant's Discovery Requests.
5. Plaintiffs' Motion has not been filed in an attempt to delaythe legalprocess.
6. Furthermore, an extension of the deadline will not prejudiceeither party.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/25/2022 01:21:29 PM.****
WHEREFORE, Plaintiffs,JERRY CANNIS AND PEGGY CANNIS, respectfully
request that this Honorable Court enter an Order grantingthis Motion for Extension of Time to
submit responses, and for any further relief this Court deems justand proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served via the
-th
Florida E-FilingPortal to: Counsel of Record for Defendant, on the 25? day of October 2022.
Your Insurance Attorney, PLLC.
2601 South Bayshore Drive 18th Floor
Coconut Grove, FL 33133
Telephone No. 1-888-570-5677
Facsimile No. 1-888-745-5677
Email: YIA3@Yourinsuranceattorney.com
Secondary Email:
Eservice@Yourinsuranceattorney.com
By: /s/ Maximo A. Santiago
Maximo A. Santiago,Esq.
Florida Bar No. 669733
Ariana Rubio Di Natale, Esq.
Florida Bar No. 1025882
Preview
Filing# 159921779 E-Filed 10/25/2022 01:21:29 PM IN THE CIRCUITCOURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JERRY CANNIS AND CASE NO.: CACE-21-016611 (09) PEGGY CANNIS, Plaintiff, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY. Defendant. ' PLAINTIFFS' FIRST MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO DEFENDANT'S EXPERT DISCOVERY REQUESTS JERRY Plaintiffs, CANNIS AND PEGGY CANNIS, by and through the undersigned counsel, hereby file this Motion requestingadditional time to respond to Defendant's Expert Discovery Requests, and in support thereof,state as follows: 1. On ,rd or about September 231 ',2022; Plaintiffs were served with Defendant's Expert Discovery Requests. 2. Plaintiffs are in need of additional time to respond to Defendant's Discovery Requests and hereby respectfully request an additional twenty (20) days to submit their responses to same. 3 The requestedextension sought herein will allow sufficient time for Plaintiffs to adequatelyrespond to Defendant's Expert Discovery Requests. 4. By filingthis Motion for Extension of Time, Plaintiffs hereby reserve the rightto assert any and all objectionsto Defendant's Discovery Requests. 5. Plaintiffs' Motion has not been filed in an attempt to delaythe legalprocess. 6. Furthermore, an extension of the deadline will not prejudiceeither party. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/25/2022 01:21:29 PM.**** WHEREFORE, Plaintiffs,JERRY CANNIS AND PEGGY CANNIS, respectfully request that this Honorable Court enter an Order grantingthis Motion for Extension of Time to submit responses, and for any further relief this Court deems justand proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy o f the foregoingwas served via the -th Florida E-FilingPortal to: Counsel of Record for Defendant, on the 25? day of October 2022. Your Insurance Attorney, PLLC. 2601 South Bayshore Drive 18th Floor Coconut Grove, FL 33133 Telephone No. 1-888-570-5677 Facsimile No. 1-888-745-5677 Email: YIA3@Yourinsuranceattorney.com Secondary Email: Eservice@Yourinsuranceattorney.com By: /s/ Maximo A. Santiago Maximo A. Santiago,Esq. Florida Bar No. 669733 Ariana Rubio Di Natale, Esq. Florida Bar No. 1025882