On July 30, 2015 a
Motion for Extension of Time - Party: Defendant Heritage Property And Casualty Ins Comp
was filed
involving a dispute between
Edell, Benjamin,
Edell, Rebecca,
and
Heritage Property And Casualty Ins Comp,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 31456514 E-Filed 08/28/2015 02:47:36 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR BROWARD
COUNTY, FLORIDA
Case No. CACE 15-013539 21
BENJAMIN EDELL AND REBECCA
EDELL,
Plaintiffs,
vs.
HERITAGE PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT
COMES NOW, Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE
COMPANY, by and through its undersigned counsel, and hereby files its Motion for
Extension of time to Respond to Plaintiffs’ Complaint, and states as follows:
1. The Complaint in this matter was served by the Chief Financial Officer of the
State of Florida upon Defendant herein on August 12, 2015.
2. Accordingly, a responsive pleading is due on or before September 1, 2015.
3. Due to the recent retention of undersigned counsel herein, additional time is
necessary to file the appropriate responsive pleading to the Plaintiffs’ Complaint herein. In
this regard, Defendant would ask for additional thirty (30) days with which to respond to
the Plaintiffs’ Complaint.
4, No prejudice will be occasioned by any party should the Court grant the
aforementioned requested relief and allow a responsive pleading to be filed by Defendant
herein by or before October 1, 2015.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/28/2015 2:47:36 PM.****5. This motion is not made for the purposes of undue delay.
WHEREFORE, Defendant, herein, respectfully requests this Honorable Court
grant its Motion for Extension of Time, and order such further relief as the Court deems
just and proper under the circumstances.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished
by e-mail to David Low, Esquire, eservice@davidlowpa.com David Low & Associates,
P.A., 20195 Northeast 16 Place, Second Place, Miami, FL 33179, 305/935-8986, this 28"
day of August, 2015.
By. /s/ Glenn H. Malin
GLENN H. MALIN
Florida Bar # 974595
PETERSON BERNARD
Attorneys for Defendant
707 S.E. 3% Avenue, Suite 500
Fort Lauderdale, Florida 33316
(954) 763-3200
(954) 728-9019 facsimile
gmalin@ftLlaw.com
guarente@ftl-law.com
GHM:
2876.91250
Document Filed Date
August 28, 2015
Case Filing Date
July 30, 2015
Category
Contract and Indebtedness
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Filing # 31456514 E-Filed 08/28/2015 02:47:36 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No. CACE 15-013539 21 BENJAMIN EDELL AND REBECCA EDELL, Plaintiffs, vs. HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT COMES NOW, Defendant, HERITAGE PROPERTY & CASUALTY INSURANCE COMPANY, by and through its undersigned counsel, and hereby files its Motion for Extension of time to Respond to Plaintiffs’ Complaint, and states as follows: 1. The Complaint in this matter was served by the Chief Financial Officer of the State of Florida upon Defendant herein on August 12, 2015. 2. Accordingly, a responsive pleading is due on or before September 1, 2015. 3. Due to the recent retention of undersigned counsel herein, additional time is necessary to file the appropriate responsive pleading to the Plaintiffs’ Complaint herein. In this regard, Defendant would ask for additional thirty (30) days with which to respond to the Plaintiffs’ Complaint. 4, No prejudice will be occasioned by any party should the Court grant the aforementioned requested relief and allow a responsive pleading to be filed by Defendant herein by or before October 1, 2015. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/28/2015 2:47:36 PM.****5. This motion is not made for the purposes of undue delay. WHEREFORE, Defendant, herein, respectfully requests this Honorable Court grant its Motion for Extension of Time, and order such further relief as the Court deems just and proper under the circumstances. WE HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by e-mail to David Low, Esquire, eservice@davidlowpa.com David Low & Associates, P.A., 20195 Northeast 16 Place, Second Place, Miami, FL 33179, 305/935-8986, this 28" day of August, 2015. By. /s/ Glenn H. Malin GLENN H. MALIN Florida Bar # 974595 PETERSON BERNARD Attorneys for Defendant 707 S.E. 3% Avenue, Suite 500 Fort Lauderdale, Florida 33316 (954) 763-3200 (954) 728-9019 facsimile gmalin@ftLlaw.com guarente@ftl-law.com GHM: 2876.91250