Motion,Ex Parte: Adriana Hincapie, et al Plaintiff vs. Joseph Bernard Wezkiewicz, Jr., et al Defendant

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                                Filing# 151394177 E-Filed 06/13/2022 03:48:26                PM


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

                                                            CASE NO- CACE 21-016648       (14)

        ADRIANA HINCAPIE AND NICOLAS
        HINCAPIE,

               Plaintiffs,
        VS.


        JOSEPH BERNARD WEZKIEWICZ,

               Defendant.
                                                      i



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

               COMES NOW,            the Defendant,       JOSEPH BERNARD WEZKIEWICZ                (hereinafter


        "Defendant"),by and through his undersigned attorneys, and moves         this   Honorable Court for an

        extension of time within which to respond to the discovery propounded by the Plaintiffs,


        ADRIANA HINCAPIE AND NICOLAS HINCAPIE (hereinafter"Plaintiffs"),
                                                                      and as grounds


        thereof,states as follows:


                1.      The   Plaintiffs served a set                                    and Expert Witness
                                                          of Expert Witness Interrogatories


        Request for Production to the Defendant on         May   13,2022.

               2.       Pursuant to the Florida Rules o f Civil Procedure, the Defendant' s responses and


        answers are due on or before June 13,2022.


               3        The undersigned counsel's paralegalwill be on vacation and unavailable from

        Tuesday, June 14,2022 through Friday,June 24,2022.




          *** FILED:   BROWARD COUNTY,      FL   BRENDA D. FORMAN, CLERK 06/13/2022 03:48:25      PM.****
                                                                       CASE NO- CACE 21-016648                (14)


         4.       Based upon the foregoing,the undersigned requests an additional thirty(30) days

within which to respond to the Plaintiffs' Expert Witness Interrogatories
                                                                        and Expert Witness


Request for Production.

         WHEREFORE,        the   Defendant,   JOSEPH BERNARD WEZKIEWICZ,                             respectfully

requests that this Court enter an Order granting the Defendant an additional thirty(30) days


within which to respond to Plaintiffs' Expert Witness Interrogatoriesand Expert Witness


Request for Production, and for any and       all further relief that this      Honorable Court deems just

and proper in the premises.


         I    HEREBY CERTIFY that  on June 13, 2022, the foregoing was electronicallyfiled with
the Florida Courts E-Filing Portal and that as a registered   participantof the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Miriam        Fresco
               Agrait, Esq. eservice@rubensteinlaw.com,lbanciella@rubensteinlaw.com,
mfagrait@rubensteinlaw.com,Rubenstein Law, P.A., 9130 S. Dadeland Blvd, PH, Miami, FL
33156.


                                                NICHOLAS J. RYAN & ASSOCIATES
                                                 110   S. E. 6th    Street,Suite 2100
                                                Fort Lauderdale,        FL 33301
                                                Telephone: (954) 627-9401
                                                E-mail for service (FL R. Jud. Admin. 2.516).
                                                flor.law-shericritelli.2980 19@statefarm.com



                                                 Juul.CiADU
                                                Sheri L. Critelli,
                                                                 Esq.
                                                Florida Bar No.. 813508

                                                Attorney for Defendant

                                                Attorneys and Staff of Nicholas J.  Ryan &  Associates are Employees
                                                of the   Law   Department of State Farm Mutual Automobile Insurance
                                                Company