On January 06, 2001 a
Motion,Ex Parte
was filed
involving a dispute between
Grijak, Alexander,
and
Jw Marriott Marquis Miami,
Met Ii Hotel, Llc,
for Comm Premises Liability
in the District Court of Miami-Dade County.
Preview
Filing # 60781610 E-Filed 08/23/2017 11:04:31 AM
IN THE CIRCUIT COURT OF THE
11" JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: 2017-014536-CA-01
ALEXANDER GRIJAK
Plaintiff,
VS.
MET II HOTEL, LLC.,
d/b/a, JW MARRIOTT MARQUIS MIAMI
Defendant.
/
MOTION FOR ENLARGMENT OF TIME TO RESPOND
TO DEFENDANT’S DISCOVERY
Comes Now the Plaintiff, by and through undersigned counsel and hereby files the
above-styled motion and as grounds therefore states as follows:
1. On or about July 24" 2017 the Defendant propounded its Request for Production,
and Interrogatories upon the Plaintiff.
2. At present, Plaintiffis making diligent efforts to respond to Defendant’s discovery
requests.
3. Plaintiff continues to attain the necessary information and documents to respond
to Defendant’s discovery requests.
4. Plaintiff requires additional time beyond thirty (30) days within which to prepare
discovery responses.
5. Plaintiff expressly reserves the right to object to discovery requests.
6 This motion is made in good faith and is not made for the purpose of harassment
or delay.WHEREFORE, Plaintiff respectfully requests that this Court grant its Motion for
Enlargement of Time to Respond to Defendant’s Request for Production, and such other and
further relief this Court deems appropriate.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was e mailed this
23" day of August, 2017 to: Law Office of Hugh Behan, Defendant’s attorney, at
usz.slfti@zurichna.com
ROBERT W. RODRIGUEZ, P.A.
Counsel for Plaintiff
5001 SW 74 Court, Suite 105
Miami, Florida 33155
Telephone: (305) 444-1446
Facsimile (305) 907-5244
E-Serve:
RobertWRodriguez@GMail Com
/s/Robert W. Redriguez
Robert W. Rodriguez, Esq.
Florida Bar No.: 856975
Document Filed Date
August 23, 2017
Case Filing Date
January 06, 2001
Category
Comm Premises Liability
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Filing # 60781610 E-Filed 08/23/2017 11:04:31 AM IN THE CIRCUIT COURT OF THE 11" JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 2017-014536-CA-01 ALEXANDER GRIJAK Plaintiff, VS. MET II HOTEL, LLC., d/b/a, JW MARRIOTT MARQUIS MIAMI Defendant. / MOTION FOR ENLARGMENT OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY Comes Now the Plaintiff, by and through undersigned counsel and hereby files the above-styled motion and as grounds therefore states as follows: 1. On or about July 24" 2017 the Defendant propounded its Request for Production, and Interrogatories upon the Plaintiff. 2. At present, Plaintiffis making diligent efforts to respond to Defendant’s discovery requests. 3. Plaintiff continues to attain the necessary information and documents to respond to Defendant’s discovery requests. 4. Plaintiff requires additional time beyond thirty (30) days within which to prepare discovery responses. 5. Plaintiff expressly reserves the right to object to discovery requests. 6 This motion is made in good faith and is not made for the purpose of harassment or delay.WHEREFORE, Plaintiff respectfully requests that this Court grant its Motion for Enlargement of Time to Respond to Defendant’s Request for Production, and such other and further relief this Court deems appropriate. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was e mailed this 23" day of August, 2017 to: Law Office of Hugh Behan, Defendant’s attorney, at usz.slfti@zurichna.com ROBERT W. RODRIGUEZ, P.A. Counsel for Plaintiff 5001 SW 74 Court, Suite 105 Miami, Florida 33155 Telephone: (305) 444-1446 Facsimile (305) 907-5244 E-Serve: RobertWRodriguez@GMail Com /s/Robert W. Redriguez Robert W. Rodriguez, Esq. Florida Bar No.: 856975