On October 15, 2019 a
Motion for Extension of Time - Party: Plaintiff Rodriguez, Paul
was filed
involving a dispute between
Rodriguez, Paul,
and
Citizens Property Insurance Corporation,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 101065533 E-Filed 01/03/2020 09:40:41 AM
IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA
PAUL RODRIGUEZ, CASENO. CACE-19-021427 Div: 02
Plaintiff,
v.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
MOTION FOR EXTENSION OF TIME
Florida Bar #218261
COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby requests this
Honorable Court for an extension of time to respond to discovery, and as grounds therefore would
state:
1, Defendant served Interrogatories and Request for Production, service date December
3, 2019.
2. Plaintiff requires additional time to confer with counsel to properly respond to said
discovery.
3. Defendant will not be prejudiced by the granting of this motion.
4, In the utmost of caution in the event that this motion is denied without further
opportunity within which to respond , then, Plaintiff hereby objects to each and every
interrogatory and request for production as not being relevant, burdensome,
harassing, oppressive, and not calculated to lead to any discoverable or admissible
evidence; However, Plaintiff hereby reserves the right to amend or withdraw these
objections.
DUBOFF
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/03/2020 09:40:41 AM.****WHEREFORE, Plaintiff moves this Honorable Court for an extension of time to respond to
the above described discovery.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that on this 3rd day of January, 2020, a true and correct copy of
the foregoing was emailed electronically filed and served through the Florida Court’s E-Filing Portal
to: Lyndsay D. Fichtenbaum, of GOEDE, ADAMCZYK, DEBOEST & CROSS, PLLC, 4800 N.
Federal Highway, Suite 307D, Boca Raton, Florda, 334131, at |fichtenbaum@gadclaw;
bblotz@gadclaw..
DusorF Law FiRM
ATTORNEYS FOR PLAINTIFF
680 NE 127 STREET
NORTH MIAMI, FLORIDA 33161
TELEPHONE (305) 899-0085
FAx No. (305) 899-0091
COURTDOCUMENT@DUBOFFLAWFIRM.COM
y
By: 7
‘TH R. DUBOFF
Fla. Bar #218261
DUBOFF
Document Filed Date
January 03, 2020
Case Filing Date
October 15, 2019
Category
Other - Insurance Claim
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Filing # 101065533 E-Filed 01/03/2020 09:40:41 AM IN THE CIRCUIT COURT IN AND FOR BROWARD COUNTY, FLORIDA PAUL RODRIGUEZ, CASENO. CACE-19-021427 Div: 02 Plaintiff, v. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. MOTION FOR EXTENSION OF TIME Florida Bar #218261 COMES NOW Plaintiff, by and through the undersigned attorneys, and hereby requests this Honorable Court for an extension of time to respond to discovery, and as grounds therefore would state: 1, Defendant served Interrogatories and Request for Production, service date December 3, 2019. 2. Plaintiff requires additional time to confer with counsel to properly respond to said discovery. 3. Defendant will not be prejudiced by the granting of this motion. 4, In the utmost of caution in the event that this motion is denied without further opportunity within which to respond , then, Plaintiff hereby objects to each and every interrogatory and request for production as not being relevant, burdensome, harassing, oppressive, and not calculated to lead to any discoverable or admissible evidence; However, Plaintiff hereby reserves the right to amend or withdraw these objections. DUBOFF *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/03/2020 09:40:41 AM.****WHEREFORE, Plaintiff moves this Honorable Court for an extension of time to respond to the above described discovery. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that on this 3rd day of January, 2020, a true and correct copy of the foregoing was emailed electronically filed and served through the Florida Court’s E-Filing Portal to: Lyndsay D. Fichtenbaum, of GOEDE, ADAMCZYK, DEBOEST & CROSS, PLLC, 4800 N. Federal Highway, Suite 307D, Boca Raton, Florda, 334131, at |fichtenbaum@gadclaw; bblotz@gadclaw.. DusorF Law FiRM ATTORNEYS FOR PLAINTIFF 680 NE 127 STREET NORTH MIAMI, FLORIDA 33161 TELEPHONE (305) 899-0085 FAx No. (305) 899-0091 COURTDOCUMENT@DUBOFFLAWFIRM.COM y By: 7 ‘TH R. DUBOFF Fla. Bar #218261 DUBOFF