Motion,Ex Parte: Carol Pickering, et al Plaintiff vs. United Property and Casualty Insurance Company Defendant

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                                Filing# 162101797 E-Filed 11/3 0/2022 01:45:09                    PM

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

         CAROL PICKERING & JEFFREY                                     CASE NO.: CACE-21-004806
         PICKERING,

                             Plaintiffs,
         V

         UNITED PROPERTY & CASUALTY
         INSURANCE COMPANY.

                            Defendant.
                                                                   i




             PLAINTIFFS' FIRST            MOTION FOR EXTENSION OF TIME TO FILE RESPONSES
                                  TO DEFENDANT'S EXPERT DISCOVERY REQUESTS

                   Plaintiffs,CAROL         PICKERING & JEFFREY PICKERING, by                       and through the


         undersigned counsel, hereby            file   this   Motion requesting additional time       to   respond to

         Defendant's Expert Discovery Requests, and in support thereof,state as follows:


                   1.       On     or about October 13, 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 thirty(30)days to submit their responses


         to same.


                   3        The requested extension 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 Expert 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          11/30/2022 01:45:09 PM.****
          WHEREFORE,             Plaintiffs, CAROL      PICKERING      & JEFFREY            PICKERING,

           request that
respectfully                this   Honorable Court enter an Order grantingthis Motion for Extension

of Time to submit responses to Defendant's Expert 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
                                                                             )th
Florida E-FilingPortal     to:   Counsel of Record for Defendant, on the   30?     day ofNovember 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:    isi   Maximo A. Santiago
                                                         Maximo A. Santiago,Esq.
                                                         Florida Bar No. 669733
                                                         Ariana Rubio Di Natale, Esq.
                                                         Florida Bar No. 1025882