Motion,Ex Parte: Phanes Joissaint, et al Plaintiff vs. Citizens Property Insurance Corporation Defendant

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                                Filing #   133983881 E-Filed 09/02/2021 10:09:16 PM




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



           ANDRELIE PHANES and                                                    CASE NO.: CACE-21-009224 (02)
           PHANES        JOISSAINT,

                    Plaintiffs,

           VS.



           CITIZENS PROPERTY INSURANCE
           CORPORATION,

                    Defendant.
                                                                i


            DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY


                    Defendant,     CITIZENS PROPERTY INSURANCE CORPORATION                                   ("Citizens"), by

           and   through undersigned counsel, hereby files          its Motion for Extension of Time to             Respond       to



           Discovery, and would     state as    follows:


                    1.      Defendant     was   served with Plaintiffs'       Request      for Production and First Set of


                            Interrogatories.

                    2.      Defendant is in need of additional time to confer with client and                       compile   the


                            documentationand responses to           properly respond to       said    discovery.

                    3       Defendant's Motion for Extension of Time has not been filed in                         an   attempt   to



                            delay the legal process and is filed in good faith.

                    4.      Defendant     requires   a   thirty-day (30)     extension in order to         properly complete

                            responses to Plaintiffs' discovery requests.

                    5.      This   case   is not   currently   set for   trial,    and   therefore,   Plaintiffs would not be


                            prejudiced by Defendant's request for          extension.




             ***
                   FILED: BROWARD     COUNTY, FL BRENDA D. FORMAN, CLERK 09/02/2021 10:09:16 PM.****
       WHEREFORE,        for the   reasons   set forth   above, Defendant, CITIZENS PROPERTY

INSURANCE      CORPORATION, hereby requests that            this Court grant its extension of time to


respond to discovery requests and for   any other relief this Court deems just and proper.

                               CERTIFICATE OF SERVICE


       I HEREBY CERTIFY that         on   September 2, 2021, the foregoing       was   electronically filed

through the Florida Courts E-Filing Portal which will send      a   notice of electronic filing to L. Dick


Ducheine, Esq, The Diener Firm, P.A.,     8751 W. Broward     Blvd, Suite 404, Plantation, FL 33324,




                                                         /s/ Ivelis Quinones
                                               IVELIS     QUINONES, ESQ.
                                               Florida Bar No. 127606
                                               Dean, Ringers, Morgan & Lawton, P.A.
                                               Post Office Box 2928
                                               Orlando, Florida 32802-2928
                                               Tel: 407-422-4310 Fax: 407-648-0233



                                               Maria@drml-law.com

                                               Attorneys for Defendant




                                                  2
                                                                      CASE NO:



VS.




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                    ORDER ON DEFENDANT'S MOTION FOR EXTENSION
                           OF TIME TO RESPOND TO DISCOVERY


         THIS CAUSE       having    come   before the Court          on   Defendant's Motion for Extension of


Time to      Respond to Discovery   and the Court being otherwise            fully advised in the premises, it     is


hereby

         ORDERED AND ADJUDGED that Defendant's Motion for Extension of Time is


hereby GRANTED.          Defendant shall       respond to      Plaintiffs'/'s discovery   on or   before   February

13,2015.

         DONE       AND    ORDERED             in       Miami-Dade        County,   Florida     this           day

of                              ,2015.




                                                                   Circuit Judge



         I HEREBY CERTIFY that             a   true and correct copy of the         foregoing   was    furnished   on

this           dayor                                ,
                                                        2015 to:


cc.      ,   Esq.



         ,Esq.
         Post Office Box 2928
         Orlando, FL   32802-2928
    Judicial Assistant




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