On December 18, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Flores, Luz Del Carmen,
and
Safepoint Ins Comp,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 43557682 E-Filed 07/05/2016 03:53:47 PM
IN THE CIRCUIT COURT OF THE
17'™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CIRCUIT CIVIL DIVISION
CASE NO: CACE 15-022300
LUZ DEL CARMEN FLORES,
Plaintiff,
Vv
SAFEPOINT INSURANCE COMPANY,
Defendant.
PLAINTIFFS’ MOTION FOR EXTENSION OF TIME
TO RESPOND TO DISCOVERY
COMES NOW, Plaintiff, LUZ DEL CARMEN FLORES by and through undersigned
counsel, and hereby requests this Honorable Court for an extension of time to respond to
Defendant’s First Request for Production and Defendant’s First Set of Interrogatories, and in
support thereof states as follows:
1. Defendant served Plaintiff with Defendant’s First Request for Production and
Defendant’s First Set of Interrogatories (hereafter collectively “Discovery”) on June 02,
2016.
2. In order for Plaintiff to properly respond to Defendant’s Discovery, Plaintiff's counsel
requires additional time to prepare full and complete responses to the Interrogatories and
Request for Production.
3. Defendant will not be prejudiced by the granting of this Motion.
WHEREFORE, Plaintiff, LUZ DEL CARMEN FLORES, respectfully moves this
Honorable Court for an extension of time to respond to the above-described Discovery.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/5/2016 3:53:47 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the
Clerk of Court and served via email to Jennifer Smith, Esq Cole Scott Kissane,P.A via email:
Jennifer.smith@csklegal.com and ismary.cepero@csklegal.com on this 5" day of July, 2016.
Respectfully Submitted,
BARNARD LAW OFFICES, L.P.
9655 S. Dixie Highway, Suite 200
Miami, Florida 33156
(305) 665-0000
Fax (305) 669-9666
By: /s/ Ronald A. Lacayo
Ronald A. Lacayo, Esq.
Florida Bar No.: 102704
rl@barnardlawlp.com
abarnard@pbarnardlawlp.com
cma@barnardlawlp.com
Document Filed Date
July 05, 2016
Case Filing Date
December 18, 2015
Category
Contract and Indebtedness
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Filing # 43557682 E-Filed 07/05/2016 03:53:47 PM IN THE CIRCUIT COURT OF THE 17'™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIRCUIT CIVIL DIVISION CASE NO: CACE 15-022300 LUZ DEL CARMEN FLORES, Plaintiff, Vv SAFEPOINT INSURANCE COMPANY, Defendant. PLAINTIFFS’ MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY COMES NOW, Plaintiff, LUZ DEL CARMEN FLORES by and through undersigned counsel, and hereby requests this Honorable Court for an extension of time to respond to Defendant’s First Request for Production and Defendant’s First Set of Interrogatories, and in support thereof states as follows: 1. Defendant served Plaintiff with Defendant’s First Request for Production and Defendant’s First Set of Interrogatories (hereafter collectively “Discovery”) on June 02, 2016. 2. In order for Plaintiff to properly respond to Defendant’s Discovery, Plaintiff's counsel requires additional time to prepare full and complete responses to the Interrogatories and Request for Production. 3. Defendant will not be prejudiced by the granting of this Motion. WHEREFORE, Plaintiff, LUZ DEL CARMEN FLORES, respectfully moves this Honorable Court for an extension of time to respond to the above-described Discovery. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/5/2016 3:53:47 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was e-filed with the Clerk of Court and served via email to Jennifer Smith, Esq Cole Scott Kissane,P.A via email: Jennifer.smith@csklegal.com and ismary.cepero@csklegal.com on this 5" day of July, 2016. Respectfully Submitted, BARNARD LAW OFFICES, L.P. 9655 S. Dixie Highway, Suite 200 Miami, Florida 33156 (305) 665-0000 Fax (305) 669-9666 By: /s/ Ronald A. Lacayo Ronald A. Lacayo, Esq. Florida Bar No.: 102704 rl@barnardlawlp.com abarnard@pbarnardlawlp.com cma@barnardlawlp.com