On January 26, 2018 a
Motion for Extension of Time - Party: Plaintiff Hincapie, Alcira
was filed
involving a dispute between
Hincapie, Alcira,
and
Universal Property And Casualty Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 71396404 E-Filed 04/30/2018 10:35:13 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
ALCIRA HINCAPIE, CASE NO.: CACE 18-002050
Plaintiff,
Vv.
UNIVERSAL PROPERTY &
CASUALTY INSURANCE
COMPANY,
Defendant.
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
DEFENDANT’S DISCOVERY
Plaintiff, Alcira Hincapie, by and through her undersigned counsel, hereby files this
Motion for Enlargement of Time to Respond to Defendant’s Discovery to Plaintiff, and states:
1. On or about March 29, 2018, Defendant filed its Request for Production and
Interrogatories to Plaintiff.
2. Plaintiff requires additional time to appropriately file complete responses and/or
objections to the aforementioned discovery.
3. This Motion is not filed for the purpose of harassment, obstruction or delay, and
the parties will not be prejudiced by the granting of this Motion.
WHEREFORE, Plaintiff, respectfully requests that this Court enter an Order Granting
an extension of time for Plaintiff to file her responses to Defendant’s Discovery and for such
other relief as this Court deems just and proper.
*4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 4/30/2018 10:35:14 AM.****Respectfully submitted,
Chavin Mitchell Shmuely
Attorneys for Plaintiff
P.O. Box 611867
North Miami, Florida 33261
Telephone: (866) 345-2033
Facsimile: (305) 981-1054
E-Service: pleadings@cmslawgroup.com
By: /s/ Valorie S. Chavin
Florida Bar No. 14226
E-mail: vchavin@cmslawgroup.com
James E, Mitchell
Florida Bar No. 30893
E-mail: jmitchell@cmslawgroup.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 30" day of April 2018, I electronically filed the
foregoing document with the Florida Courts E-Filing Portal. I also certify that the foregoing
document is being served this day on: Steven J. Chackman, Esq., Bernstein, Chackman, Liss,
4000 Hollywood Blvd. Suite 610 North, Hollywood, Florida 33021, at:
schackman@belrlaw.com and rchackman@bclrlaw.com, via transmission of Notices of
Electronic Filing generated by Florida Courts E-Filing Portal (eservice@myflcourtaccess.com).
/s/ Valorie S. Chavin
Valorie S. Chavin
Document Filed Date
April 30, 2018
Case Filing Date
January 26, 2018
Category
Other - Insurance Claim
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Filing # 71396404 E-Filed 04/30/2018 10:35:13 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA ALCIRA HINCAPIE, CASE NO.: CACE 18-002050 Plaintiff, Vv. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY Plaintiff, Alcira Hincapie, by and through her undersigned counsel, hereby files this Motion for Enlargement of Time to Respond to Defendant’s Discovery to Plaintiff, and states: 1. On or about March 29, 2018, Defendant filed its Request for Production and Interrogatories to Plaintiff. 2. Plaintiff requires additional time to appropriately file complete responses and/or objections to the aforementioned discovery. 3. This Motion is not filed for the purpose of harassment, obstruction or delay, and the parties will not be prejudiced by the granting of this Motion. WHEREFORE, Plaintiff, respectfully requests that this Court enter an Order Granting an extension of time for Plaintiff to file her responses to Defendant’s Discovery and for such other relief as this Court deems just and proper. *4* FILED: BROWARD COUNTY. FL BRENDA D. FORMAN, CLERK 4/30/2018 10:35:14 AM.****Respectfully submitted, Chavin Mitchell Shmuely Attorneys for Plaintiff P.O. Box 611867 North Miami, Florida 33261 Telephone: (866) 345-2033 Facsimile: (305) 981-1054 E-Service: pleadings@cmslawgroup.com By: /s/ Valorie S. Chavin Florida Bar No. 14226 E-mail: vchavin@cmslawgroup.com James E, Mitchell Florida Bar No. 30893 E-mail: jmitchell@cmslawgroup.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 30" day of April 2018, I electronically filed the foregoing document with the Florida Courts E-Filing Portal. I also certify that the foregoing document is being served this day on: Steven J. Chackman, Esq., Bernstein, Chackman, Liss, 4000 Hollywood Blvd. Suite 610 North, Hollywood, Florida 33021, at: schackman@belrlaw.com and rchackman@bclrlaw.com, via transmission of Notices of Electronic Filing generated by Florida Courts E-Filing Portal (eservice@myflcourtaccess.com). /s/ Valorie S. Chavin Valorie S. Chavin