On January 24, 2018 a
Motion for Extension of Time - TO RESPOND TO PLAINTIFF'S COMPLAINTParty: Defendant Citizens Property Insurance Corporation
was filed
involving a dispute between
Castillo, Michelle,
Harris, Phil, Iv,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 67918176 E-Filed 02/13/2018 04:19:06 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE18001865
HONORABLE CARLOS AUGUSTO RODRIGUEZ
MICHELLE CASTILLO and PHIL
HARRIS IV,
Plaintiffs,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, by and through the undersigned counsel and hereby files this Motion
for Extension of Time to respond to Plaintiffs’ Complaint, and as grounds in support
thereof states as follows:
1. This is an action for damages under a homeowner’s insurance policy resulting
from an alleged loss to Plaintiffs’ property that is alleged to have occurred on
or about August 19, 2017.
2. The Defendant was served with Plaintiffs’ Complaint on or about January 29,
2018.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/13/2018 4:19:05 PM.****3. Defendant’s counsel needs additional time to compile and review the necessary
claims documentation in order to fully and accurately respond to Plaintiffs’
Complaint.
4. Fla. R. Civ. P. 1.090(b) states, “[w]hen an act is required to be done at or
within a specified time by order of court, by these rules, or by notice given
thereunder, for cause shown the court at any time in its discretion (1) with or
without notice, may order the period enlarged if request therefore is made
before expiration of the period originally prescribed or extended by a previous
order.”
5. This matter is not set for trial and the Plaintiffs will not be prejudiced by
granting this request.
6. This request is made in good faith and without purpose of delay.
WHEREFORE, Defendant requests and moves this Court to enter an Order
allowing the Defendant additional time in which to respond to Plaintiffs’ Complaint.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
sent via E-Service to Jonathan Korin, Esq. (jonathan@korinlaw.com), Mailing Address:
7900 Oak Lane, Suite 400, Miami Lakes, FL, 33016; on February 13, 2018.
s/ Chioma R. Deere, Esq.
Chioma R. Deere, Esq. (eService@wlclaw.com)
Florida Bar No. 48950
Chris D. Connally, Esq.
Florida Bar No. 488453Attorney for Defendant Citizens Property Insurance
Corporation
Williams, Leininger & Cosby, P.A.
11300 US Highway One, Suite 300
North Palm Beach, Florida 33408
Telephone No. (561)615-5666
Facsimile No. (561)615-9606
Document Filed Date
February 13, 2018
Case Filing Date
January 24, 2018
Category
Other - Insurance Claim
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Filing # 67918176 E-Filed 02/13/2018 04:19:06 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE18001865 HONORABLE CARLOS AUGUSTO RODRIGUEZ MICHELLE CASTILLO and PHIL HARRIS IV, Plaintiffs, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME COMES NOW the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, by and through the undersigned counsel and hereby files this Motion for Extension of Time to respond to Plaintiffs’ Complaint, and as grounds in support thereof states as follows: 1. This is an action for damages under a homeowner’s insurance policy resulting from an alleged loss to Plaintiffs’ property that is alleged to have occurred on or about August 19, 2017. 2. The Defendant was served with Plaintiffs’ Complaint on or about January 29, 2018. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 2/13/2018 4:19:05 PM.****3. Defendant’s counsel needs additional time to compile and review the necessary claims documentation in order to fully and accurately respond to Plaintiffs’ Complaint. 4. Fla. R. Civ. P. 1.090(b) states, “[w]hen an act is required to be done at or within a specified time by order of court, by these rules, or by notice given thereunder, for cause shown the court at any time in its discretion (1) with or without notice, may order the period enlarged if request therefore is made before expiration of the period originally prescribed or extended by a previous order.” 5. This matter is not set for trial and the Plaintiffs will not be prejudiced by granting this request. 6. This request is made in good faith and without purpose of delay. WHEREFORE, Defendant requests and moves this Court to enter an Order allowing the Defendant additional time in which to respond to Plaintiffs’ Complaint. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been sent via E-Service to Jonathan Korin, Esq. (jonathan@korinlaw.com), Mailing Address: 7900 Oak Lane, Suite 400, Miami Lakes, FL, 33016; on February 13, 2018. s/ Chioma R. Deere, Esq. Chioma R. Deere, Esq. (eService@wlclaw.com) Florida Bar No. 48950 Chris D. Connally, Esq. Florida Bar No. 488453Attorney for Defendant Citizens Property Insurance Corporation Williams, Leininger & Cosby, P.A. 11300 US Highway One, Suite 300 North Palm Beach, Florida 33408 Telephone No. (561)615-5666 Facsimile No. (561)615-9606