On October 31, 2019 a
Motion for Extension of Time
was filed
involving a dispute between
Appleton , Latoya,
Kinsey , Ladarius,
and
Universal Property & Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
Preview
Filing # 99612984 E-Filed 12/02/2019 10:05:29 AM
IN THE CIRCUIT COURT OF THE 177
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
LATOYA APPLETON, CASE NO.: CACE-19-022618 (02)
Plaintiff(s),
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFF’S COMPLAINT
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
(“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plaintiff's Complaint, and states as follows:
1. This matter arises out of a claim asserted by Plaintiff, LATOYA APPLETON,
against Universal for damages arising out of and resulting from an alleged loss which Plaintiff
alleges occurred on or about December 10, 2018.
2. The undersigned counsel is in receipt of Plaintiffs Complaint; however, additional
time is necessary to respond and as such, Universal would respectfully request additional time to
review the file, discuss early resolution, and if necessary, file a response to Plaintiff's Complaint.
3. Defendant is requesting an extension of thirty (30) days.
4. This Motion is not being filed for the purposes of delay and will not prejudice any
party.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 10:05:29 AM.****LATOYA APPLETON and LADARIUS KINSEY vs. UPCIC
CASE NO.: CACE-19-022618 (02)
Page 2 of 2
WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests
this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to
Plaintiff’s Complaint and any and all other relief this Court may deem just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Milton Grey, Esq., Insurance Litigation Group, P.A., (service@ILGPA.com) on the
2" day of December 2019.
Attorney for Defendant
Universal Property & Casualty Ins. Co.
PO Box 9388
Fort Lauderdale, Florida 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: 954-958-1262
By:_/s/ Marcus Louis
Marcus Louis, Esq.
Florida Bar No. 1003305
For Service of Court Documents only:
Primary: upciceservice03@universalproperty.com
Secondary: sb0128@universalproperty.com
Tertiary: js0730@universalproperty.com
For Scheduling Matters:
sb0128@universalproperty.com
*Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com
or upciceservice03@universalproperty.com.
Document Filed Date
December 02, 2019
Case Filing Date
October 31, 2019
Category
Contract and Indebtedness
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Filing # 99612984 E-Filed 12/02/2019 10:05:29 AM IN THE CIRCUIT COURT OF THE 177 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA LATOYA APPLETON, CASE NO.: CACE-19-022618 (02) Plaintiff(s), vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY (“Universal”), by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plaintiff's Complaint, and states as follows: 1. This matter arises out of a claim asserted by Plaintiff, LATOYA APPLETON, against Universal for damages arising out of and resulting from an alleged loss which Plaintiff alleges occurred on or about December 10, 2018. 2. The undersigned counsel is in receipt of Plaintiffs Complaint; however, additional time is necessary to respond and as such, Universal would respectfully request additional time to review the file, discuss early resolution, and if necessary, file a response to Plaintiff's Complaint. 3. Defendant is requesting an extension of thirty (30) days. 4. This Motion is not being filed for the purposes of delay and will not prejudice any party. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/02/2019 10:05:29 AM.****LATOYA APPLETON and LADARIUS KINSEY vs. UPCIC CASE NO.: CACE-19-022618 (02) Page 2 of 2 WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to Plaintiff’s Complaint and any and all other relief this Court may deem just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Milton Grey, Esq., Insurance Litigation Group, P.A., (service@ILGPA.com) on the 2" day of December 2019. Attorney for Defendant Universal Property & Casualty Ins. Co. PO Box 9388 Fort Lauderdale, Florida 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: 954-958-1262 By:_/s/ Marcus Louis Marcus Louis, Esq. Florida Bar No. 1003305 For Service of Court Documents only: Primary: upciceservice03@universalproperty.com Secondary: sb0128@universalproperty.com Tertiary: js0730@universalproperty.com For Scheduling Matters: sb0128@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice03@universalproperty.com.