On December 18, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Manikuttiyil, Merly,
Manikuttiyil, Pious,
and
Florida Peninsula Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 36869083 E-Filed 01/22/2016 10:39:58 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD ~ COUNTY,
FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE 15-022416
PIOUS MANIKUTTIYIL AND
MERLY MANIKUTTIYIL,
Plaintiff,
FLORIDA PENINSULA INSURANCE
COMPANY,
Defendant.
/
/
MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Defendant, FLORIDA PENINSULA INSURANCE COMPANY, by and through
undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure, files this
Motion for Extension of Time to Respond to the Complaint filed herein, and as grounds therefor
states as follows:
1, Plaintiffs filed this lawsuit against Defendant and recently served Defendant with
service of process.
2. The undersigned has recently been retained by Defendant and has not been able to
review the file in order to prepare an appropriate response to the Complaint. Defendant
accordingly requests an extension of time to do so.
3. Plaintiffs will suffer no prejudice by the granting of the requested extension.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/22/2016 10:39:58 AM.****WHEREFORE, Defendant, FLORIDA PENINSULA INSURANCE COMPANY,
respectfully requests this Court enter an Order granting it an extension of time to respond to the
Complaint, and any other relief this Court deems just and proper.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the forgoing was served via
electronic service on the 22" day of January, 2016 upon: Robert A. Reynolds, Esq., Duboff Law
Firm, 680 NE 127" Street, North Miami, Florida 33161.
courldocument@dubofMawfirm.com
WOOD & ASSOCIATES
Attorneys for Defendant
9200 S. Dadeland Blvd, Ste 509
Miami, Florida 33156
Telephone (305) 670-3838
Facsimile (305) 670-1903
E-service: service@civildefenselaw.net
/s/ Hayes G. Wood
By:
HAYES G. WOOD
FLORIDA BAR NO. 377767
Document Filed Date
January 22, 2016
Case Filing Date
December 18, 2015
Category
Other - Insurance Claim
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Filing # 36869083 E-Filed 01/22/2016 10:39:58 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD ~ COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE 15-022416 PIOUS MANIKUTTIYIL AND MERLY MANIKUTTIYIL, Plaintiff, FLORIDA PENINSULA INSURANCE COMPANY, Defendant. / / MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT Defendant, FLORIDA PENINSULA INSURANCE COMPANY, by and through undersigned counsel, and pursuant to the applicable Florida Rules of Civil Procedure, files this Motion for Extension of Time to Respond to the Complaint filed herein, and as grounds therefor states as follows: 1, Plaintiffs filed this lawsuit against Defendant and recently served Defendant with service of process. 2. The undersigned has recently been retained by Defendant and has not been able to review the file in order to prepare an appropriate response to the Complaint. Defendant accordingly requests an extension of time to do so. 3. Plaintiffs will suffer no prejudice by the granting of the requested extension. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/22/2016 10:39:58 AM.****WHEREFORE, Defendant, FLORIDA PENINSULA INSURANCE COMPANY, respectfully requests this Court enter an Order granting it an extension of time to respond to the Complaint, and any other relief this Court deems just and proper. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the forgoing was served via electronic service on the 22" day of January, 2016 upon: Robert A. Reynolds, Esq., Duboff Law Firm, 680 NE 127" Street, North Miami, Florida 33161. courldocument@dubofMawfirm.com WOOD & ASSOCIATES Attorneys for Defendant 9200 S. Dadeland Blvd, Ste 509 Miami, Florida 33156 Telephone (305) 670-3838 Facsimile (305) 670-1903 E-service: service@civildefenselaw.net /s/ Hayes G. Wood By: HAYES G. WOOD FLORIDA BAR NO. 377767