On December 08, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Neblett, Beverly,
and
Florida Peninsula Ins Comp,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 36740273 E-Filed 01/19/2016 05:47:25 PM
IN THE CIRCUIT COURT OF THE 174
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
BEVERLY NEBLETT,
GENERAL JURISDICTION DIVISION
Plaintiff,
CASE NO.: CACE-15-021598 (04)
vs.
FLORIDA PENINSULA INSURANCE
COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION
j OF TIME TO RESPOND ‘TO COMPLAINT
Defendant, FLORIDA PENINSULA INSURANCE COMPANY (hereinafter “FPIC”),
by and through the undersigned counsel, and pursuant to the applicable Rules of Civil Procedure,
hereby files its Motion for Extension of Time to file its Response to Plaintiff's Complaint and, in
support thereof, Defendant states as follows:
| 1, The Complaint in this matter was served upon FPIC on December 30, 2015,
2. Undersigned counsel was recently retained to represent FPIC in this matter and
| has not yet had the opportunity to review the entire file.
3, As a result, undersigned counsel is in need of additional time within which to
prepare its response to the Complaint.
4, The undersigned will confer with counsel for Plaintiff prior to the date this motion
is heard in an effort to reach an agreement to the extension.
5. This is Defendant's first request for extension and said request is made in good
faith, in an abundance of caution, and is not intended to delay action on this matter.
6. The requested extension will not prejudice any party in this matter.
-l-
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
“ADO SREB PAROARE COUNTY Hoo RONPRRD PORES HEROD Sich abs FOP H161Beverly Neblett v, Florida Peninsula Insurance Company
Broward Circuit Court Case No. CACE-15-021598 (04)
WHEREFORE, Defendant, FLORIDA PENINSULA INSURANCE COMPANY,
respectfully requests that this Court enter an Order granting this motion and granting any further
relief this Court deems just and proper under the circumstances.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy has been sent by Email to: Erik
{ D. Diener, Esq., The Diener Firm, P.A.; service@dienerfirm.com ; on this (Sy May of January,
2016.
QUINTAIROS, PRIETO, WOOD & BOYER, P.A.
Attorneys for Defendant, FPIC
9300 South Dadeland Boulevard, 4" Floor
Miami, Florida 33156
Telephone: (305) 670-1101
Facsimile: (305) of
i
MIKAEL LAGUNA, ESO. [FBN: 94667]
i mikael.laguna@qpwblaw.com
i
For service of court documents only:
Designated Primary Email:
mlaguna.pleadings@qpwblaw.com
Designated Secondary Email:
jbosch.pleadings@qpwhlaw.com
-2-
QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW
9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-1161
Document Filed Date
January 19, 2016
Case Filing Date
December 08, 2015
Category
Other - Insurance Claim
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Filing # 36740273 E-Filed 01/19/2016 05:47:25 PM IN THE CIRCUIT COURT OF THE 174 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BEVERLY NEBLETT, GENERAL JURISDICTION DIVISION Plaintiff, CASE NO.: CACE-15-021598 (04) vs. FLORIDA PENINSULA INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION j OF TIME TO RESPOND ‘TO COMPLAINT Defendant, FLORIDA PENINSULA INSURANCE COMPANY (hereinafter “FPIC”), by and through the undersigned counsel, and pursuant to the applicable Rules of Civil Procedure, hereby files its Motion for Extension of Time to file its Response to Plaintiff's Complaint and, in support thereof, Defendant states as follows: | 1, The Complaint in this matter was served upon FPIC on December 30, 2015, 2. Undersigned counsel was recently retained to represent FPIC in this matter and | has not yet had the opportunity to review the entire file. 3, As a result, undersigned counsel is in need of additional time within which to prepare its response to the Complaint. 4, The undersigned will confer with counsel for Plaintiff prior to the date this motion is heard in an effort to reach an agreement to the extension. 5. This is Defendant's first request for extension and said request is made in good faith, in an abundance of caution, and is not intended to delay action on this matter. 6. The requested extension will not prejudice any party in this matter. -l- QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW “ADO SREB PAROARE COUNTY Hoo RONPRRD PORES HEROD Sich abs FOP H161Beverly Neblett v, Florida Peninsula Insurance Company Broward Circuit Court Case No. CACE-15-021598 (04) WHEREFORE, Defendant, FLORIDA PENINSULA INSURANCE COMPANY, respectfully requests that this Court enter an Order granting this motion and granting any further relief this Court deems just and proper under the circumstances. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy has been sent by Email to: Erik { D. Diener, Esq., The Diener Firm, P.A.; service@dienerfirm.com ; on this (Sy May of January, 2016. QUINTAIROS, PRIETO, WOOD & BOYER, P.A. Attorneys for Defendant, FPIC 9300 South Dadeland Boulevard, 4" Floor Miami, Florida 33156 Telephone: (305) 670-1101 Facsimile: (305) of i MIKAEL LAGUNA, ESO. [FBN: 94667] i mikael.laguna@qpwblaw.com i For service of court documents only: Designated Primary Email: mlaguna.pleadings@qpwblaw.com Designated Secondary Email: jbosch.pleadings@qpwhlaw.com -2- QUINTAIROS, PRIETO, WOOD & BOYER, P.A., ATTORNEYS AT LAW 9300 South Dadeland Boulevard, 4th Floor, Miami, Florida 33156 - Tel: (305) 670-1101 - Fax: (305) 670-1161