On August 31, 2021 a
Motion for Extension of Time - TO FILE RESPONSES TO DEFENDANT'S INITIAL DISCOVERY REQUESTSParty: Plaintiff Cannis, Jerry Plaintiff Cannis, Peggy
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# 152336450 E-Filed 06/28/2022 01:48:28 PM
IN THE CIRCUITCOURT FOR THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JERRY CANNIS & PEGGY CANNIS, CASE NO.: CACE-21-016611
Plaintiffs,
V
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
i
PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE
RESPONSES TO DEFENDANT'S INITIAL DISCOVERY REQUESTS
JERRY
Plaintiffs, CANNIS & PEGGY CANNIS, by and through the undersigned counsel,
hereby file this Motion requestingadditional time to respond to Defendant's Initial Discovery
Requests, and in support thereof,state as follows:
1. On or about May 24, 2022; Plaintiffs were served with Defendant's Initial
Discovery Requests.
2. Plaintiffs are in need of additional time to respond to Defendant's Initial Discovery
Requests and hereby respectfully
request an additional forty(40)days to submit their responses to
same.
3 The requested extension sought herein will allow sufficient time for Plaintiffs to
adequatelyrespond to Defendant's Initial 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 06/28/2022 01:48:28 PM.****
WHEREFORE, JERRY
Plaintiffs, CANNIS & PEGGY CANNIS, respectfully
request
that this Honorable Court enter an Order grantingthis Motion for Extension of Time to submit
responses to Defendant's Initial Discovery Requests, 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
Florida E-FilingPortal to: Counsel ofRecordfbr Detendant, on the 28th day of June 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@Yourinsuranceattomey.com
By: Is, Maximo31. Santiago
Maximo A. Santiago,Esq.
Florida Bar No. 669733
Ariana Rubio Di Natale, Esq.
Florida Bar No. 1025882
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Filing# 152336450 E-Filed 06/28/2022 01:48:28 PM IN THE CIRCUITCOURT FOR THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JERRY CANNIS & PEGGY CANNIS, CASE NO.: CACE-21-016611 Plaintiffs, V UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. i PLAINTIFFS' MOTION FOR EXTENSION OF TIME TO FILE RESPONSES TO DEFENDANT'S INITIAL DISCOVERY REQUESTS JERRY Plaintiffs, CANNIS & PEGGY CANNIS, by and through the undersigned counsel, hereby file this Motion requestingadditional time to respond to Defendant's Initial Discovery Requests, and in support thereof,state as follows: 1. On or about May 24, 2022; Plaintiffs were served with Defendant's Initial Discovery Requests. 2. Plaintiffs are in need of additional time to respond to Defendant's Initial Discovery Requests and hereby respectfully request an additional forty(40)days to submit their responses to same. 3 The requested extension sought herein will allow sufficient time for Plaintiffs to adequatelyrespond to Defendant's Initial 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 06/28/2022 01:48:28 PM.**** WHEREFORE, JERRY Plaintiffs, CANNIS & PEGGY CANNIS, respectfully request that this Honorable Court enter an Order grantingthis Motion for Extension of Time to submit responses to Defendant's Initial Discovery Requests, 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 Florida E-FilingPortal to: Counsel ofRecordfbr Detendant, on the 28th day of June 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@Yourinsuranceattomey.com By: Is, Maximo31. Santiago Maximo A. Santiago,Esq. Florida Bar No. 669733 Ariana Rubio Di Natale, Esq. Florida Bar No. 1025882