On July 30, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Augustin, Moise,
Augustin, Rosette,
and
Citizens Prop Ins Corp,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 31969148 E-Filed 09/11/2015 03:19:45 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE 15 013575 DIV 09
MOISE AUGUSTIN AND
ROSETTE AUGUSTIN,
Plaintiff(s),
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant(s)
DEFENDANT’S OTOH FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFFS’ COMPLAINT
The Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, [hereinafter
“Defendant”], by and through the undersigned counsel, hereby files this Motion for Extension of
Time to Respond to Plaintiffs’ Complaint, and in support thereof states as follows:
1. The Defendant was purportedly served with Plaintiffs’ Complaint for Damages on
or about August 24", 2015.
2. Undersigned counsel was recently retained to represent the Defendant and needs
additional time to review this matter, assess the claims file and obtain all
appropriate documents in order to adequately and properly respond to, and/or
address the Complaint in this action.
This motion is made in good faith and is in no way designed to prejudice the
we
rights of either party or to delay the ultimate resolution of this case.
4. A good faith effort will be made to resolve the subject matter of this motion with
opposing counsel prior to a hearing on the matter.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/11/2015 3:19:46 PM.****WHEREFORE, the Defendant, CITIZENS PROPERTY INSURANCE
CORPORATION, respectfully requests that this Honorable Court grant it an extension of time
within which to respond to Plaintiffs’ Complaint for Damages and grant all other relief deemed
appropriate.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
electronic mail this 11" day of September, 2015 to: Thomas J. Morgan, Jr., Morgan Law Group,
55 Merrick Way, Suite 404, Coral Gables Fl 33134
ISRIEL PONZOLI & SIMPSON, P.A.
Attorneys for Citizens Property Insurance Corp.
2121 S.W. 3 Avenue — 7" Floor
Miami, Florida 33129
Telephone: (305) 577-4800
Facsimile: (305) 577-4808
Email: byosef@ips-law.com
By: _s/Brian Yosef.
Brian Yosef, Esq.
Florida Bar No. 31179
Document Filed Date
September 11, 2015
Case Filing Date
July 30, 2015
Category
Contract and Indebtedness
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Filing # 31969148 E-Filed 09/11/2015 03:19:45 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE 15 013575 DIV 09 MOISE AUGUSTIN AND ROSETTE AUGUSTIN, Plaintiff(s), CITIZENS PROPERTY INSURANCE CORPORATION, Defendant(s) DEFENDANT’S OTOH FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT The Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, [hereinafter “Defendant”], by and through the undersigned counsel, hereby files this Motion for Extension of Time to Respond to Plaintiffs’ Complaint, and in support thereof states as follows: 1. The Defendant was purportedly served with Plaintiffs’ Complaint for Damages on or about August 24", 2015. 2. Undersigned counsel was recently retained to represent the Defendant and needs additional time to review this matter, assess the claims file and obtain all appropriate documents in order to adequately and properly respond to, and/or address the Complaint in this action. This motion is made in good faith and is in no way designed to prejudice the we rights of either party or to delay the ultimate resolution of this case. 4. A good faith effort will be made to resolve the subject matter of this motion with opposing counsel prior to a hearing on the matter. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/11/2015 3:19:46 PM.****WHEREFORE, the Defendant, CITIZENS PROPERTY INSURANCE CORPORATION, respectfully requests that this Honorable Court grant it an extension of time within which to respond to Plaintiffs’ Complaint for Damages and grant all other relief deemed appropriate. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via electronic mail this 11" day of September, 2015 to: Thomas J. Morgan, Jr., Morgan Law Group, 55 Merrick Way, Suite 404, Coral Gables Fl 33134 ISRIEL PONZOLI & SIMPSON, P.A. Attorneys for Citizens Property Insurance Corp. 2121 S.W. 3 Avenue — 7" Floor Miami, Florida 33129 Telephone: (305) 577-4800 Facsimile: (305) 577-4808 Email: byosef@ips-law.com By: _s/Brian Yosef. Brian Yosef, Esq. Florida Bar No. 31179