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Filing # 74254671 E-Filed 06/28/2018 02:49:34 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
THOMAS ROSS, CASE NO.: CACE18000308 (03)
Plaintiff,
vs.
BRIAN LIEFER AND GEICO
GENERAL INSURANCE COMPANY,
Defendants.
/
DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND
TO COMPLAINT
COMES NOW, the Defendant, BRIAN W. LIEFER, by and through his undersigned
counsel, and in accordance with the appropriate Rule of Civil Procedure hereby files this Motion
for Extension of Time to file a response to the Plaintiff's Complaint herein and states as follows:
1. The Defendant's attorney has not had sufficient time to research the issues and respond
to the Plaintiff's Complaint.
2. The office of the Defendant's attorney contacted the Plaintiff's attorney office to
request an extension of time to respond to the Plaintiff's Complaint and Plaintiff's attorney office
refused to agree to an extension.
3. The undersigned has not had time to speak with the Defendant and discuss the facts,
defenses, and other issues, so that an intelligent and lawful response can be filed with the Court.
4. Tt should be noted that the address of the Defendant, BRIAN W. LIEFER, is Junction
Texas.
5. It appears that the Defendant is in the Military.
6. Therefore, the undersigned requests 30 days in order to file a responsive pleading.
WHEREFORE, the Defendant, BRIAN W. LIEFER, requests this Honorable Court grant a
30 day extension to respond to Plaintiff's Complaint.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/28/2018 2:49:35 PM.****I HEREBY CERTIFY that on June 28, 2018, the foregoing was electronically filed with the Florida
Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through
the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Trelvis D. Randolph, Esq.
trelvis.randolph@csklegal.com, ileana.machado@csklegal.com, alina.gonzalez@csklegal.com, Cole, Scott
& Kissane, P.A., 9150 S. Dadeland Boulevard, Suite 1400, Miami, FL 33256 and Malcolm A. Purow, Esq. ,
Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Fort Lauderdale, FL 33308.
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-chuckbenson.295019@statefarm.com
<>
a
Charles E. Benson, Esq.
Florida Bar No.: 974056
Attorney for Defendant, Brian Liefer
Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of the
Law Department of State Farm Mutual Automobile Insurance Company
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Filing # 74254671 E-Filed 06/28/2018 02:49:34 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA THOMAS ROSS, CASE NO.: CACE18000308 (03) Plaintiff, vs. BRIAN LIEFER AND GEICO GENERAL INSURANCE COMPANY, Defendants. / DEFENDANT'S MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT COMES NOW, the Defendant, BRIAN W. LIEFER, by and through his undersigned counsel, and in accordance with the appropriate Rule of Civil Procedure hereby files this Motion for Extension of Time to file a response to the Plaintiff's Complaint herein and states as follows: 1. The Defendant's attorney has not had sufficient time to research the issues and respond to the Plaintiff's Complaint. 2. The office of the Defendant's attorney contacted the Plaintiff's attorney office to request an extension of time to respond to the Plaintiff's Complaint and Plaintiff's attorney office refused to agree to an extension. 3. The undersigned has not had time to speak with the Defendant and discuss the facts, defenses, and other issues, so that an intelligent and lawful response can be filed with the Court. 4. Tt should be noted that the address of the Defendant, BRIAN W. LIEFER, is Junction Texas. 5. It appears that the Defendant is in the Military. 6. Therefore, the undersigned requests 30 days in order to file a responsive pleading. WHEREFORE, the Defendant, BRIAN W. LIEFER, requests this Honorable Court grant a 30 day extension to respond to Plaintiff's Complaint. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 6/28/2018 2:49:35 PM.****I HEREBY CERTIFY that on June 28, 2018, the foregoing was electronically filed with the Florida Courts E-Filing Portal and that as a registered participant of the Portal I have effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on Trelvis D. Randolph, Esq. trelvis.randolph@csklegal.com, ileana.machado@csklegal.com, alina.gonzalez@csklegal.com, Cole, Scott & Kissane, P.A., 9150 S. Dadeland Boulevard, Suite 1400, Miami, FL 33256 and Malcolm A. Purow, Esq. , Steinger, Iscoe & Greene, P.A., 2400 E. Commercial Blvd., Suite 900, Fort Lauderdale, FL 33308. 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-chuckbenson.295019@statefarm.com <> a Charles E. Benson, Esq. Florida Bar No.: 974056 Attorney for Defendant, Brian Liefer Attomeys and Staff of Nicholas J. Ryan & Associates are Employees of the Law Department of State Farm Mutual Automobile Insurance Company