On January 09, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Leyva, Aracelys,
Multimed Care, Inc.,
and
Geico General Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
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Filing # 92734892 E-Filed 07/17/2019 05:24:54 PM
IN THE COUNTY COURT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE # 19-000629 CC 26
MULTIMED CARE, INC.
AIA/O ARACELYS LEYVA,
Plaintiff,
v.
GEICO GENERAL
INSURANCE COMPANY,
Defendant.
/
PLAINTIFF’S EX-PARTE MOTION
TO COMPEL DISCOVERY
(Expert interrogatories)
Plaintiff, by and through its undersigned counsel, files and serves this Ex-Parte
Motion to Compel Discovery and states as follows:
41. On 06/01/19 Plaintiff served Defendant with its Expert Interrogatories.
2. To date, Defendant has failed to contact the undersigned, move for an
additional enlargement of time to respond to Plaintiff's discovery, respond to said
discovery, seek a protective order, or file objections thereto.
3. Plaintiff is entitled to discovery and an Order compelling Defendant to
respond to its Expert Interrogatories.
4. Accordingly, Plaintiff respectfully requests the entry of an Order
compelling the Defendant to respond to its outstanding discovery.WHEREFORE, Plaintiff respectfully request this Honorable Court to enter an
Order compelling Defendant to respond to Plaintiff's Expert interrogatories within ten
(10) days frorn the date of the entry of an Order compelling same.
Respectfully submitted,
MAJID VOSSOUGHI, P.A.
Attorneys for Plaintiff
3620 N.W. 7% Street
Miami, Florida 33125
Telephone: (305) 642-2661
Facsimile: (305) 642-6881
A,
By:
MAND VOSSOUSH
Fla. Bar No. 0277370
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
email on this (uh day of Tide 2019 to MANUEL MENDOZA, ESQ., Law
Office of Haydee De La Rosa-Tolgyesi, 2600 Douglas Road, Suite 700, Coral Gables,
Florida 33134, Miamivivasico@ec:
B.Com,
“
w | i.
MAJID OSSOUGpilIN THE COUNTY COURT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
CIVIL DIVISION
CASE # 19-000629 CC 26
MULTIMED CARE, INC.
AIAIO ARACELYS LEYVA,
Plaintiff,
v.
GEICO GENERAL
INSURANCE COMPANY,
Defendant.
/
ORDER ON PLAINTIFF'S EX-PARTE
MOTION TO COMPEL DISCOVERY
(Expert interrogatories)
THIS CAUSE having come before the court upon Plaintiffs Ex-Parte Motion to
Compel Discovery, and the Court having considered same, it is hereby;
ORDERED AND ADJUDGED that Plaintiff's Ex-Parte Motion to Compel
Discovery is hereby GRANTED. Defendant shall have ten (10) days from the date of
this Order to respond to Plaintiff's Expert Interrogatories. Failure to comply with this
order may result in an appropriate order as enumerated under Florida Rules of Civil
procedure 1.380(b)(2).
DONE AND ORDERED in chambers, at Miami-Dade County, Florida, this
day of » 2019.
Copies furnished to: COUNTY COURT JUDGE
Counsel of Record
Document Filed Date
July 17, 2019
Case Filing Date
January 09, 2019
Category
Personal Injury Protection ($8,001 - $15,000)
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Filing # 92734892 E-Filed 07/17/2019 05:24:54 PM IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE # 19-000629 CC 26 MULTIMED CARE, INC. AIA/O ARACELYS LEYVA, Plaintiff, v. GEICO GENERAL INSURANCE COMPANY, Defendant. / PLAINTIFF’S EX-PARTE MOTION TO COMPEL DISCOVERY (Expert interrogatories) Plaintiff, by and through its undersigned counsel, files and serves this Ex-Parte Motion to Compel Discovery and states as follows: 41. On 06/01/19 Plaintiff served Defendant with its Expert Interrogatories. 2. To date, Defendant has failed to contact the undersigned, move for an additional enlargement of time to respond to Plaintiff's discovery, respond to said discovery, seek a protective order, or file objections thereto. 3. Plaintiff is entitled to discovery and an Order compelling Defendant to respond to its Expert Interrogatories. 4. Accordingly, Plaintiff respectfully requests the entry of an Order compelling the Defendant to respond to its outstanding discovery.WHEREFORE, Plaintiff respectfully request this Honorable Court to enter an Order compelling Defendant to respond to Plaintiff's Expert interrogatories within ten (10) days frorn the date of the entry of an Order compelling same. Respectfully submitted, MAJID VOSSOUGHI, P.A. Attorneys for Plaintiff 3620 N.W. 7% Street Miami, Florida 33125 Telephone: (305) 642-2661 Facsimile: (305) 642-6881 A, By: MAND VOSSOUSH Fla. Bar No. 0277370 CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was sent via email on this (uh day of Tide 2019 to MANUEL MENDOZA, ESQ., Law Office of Haydee De La Rosa-Tolgyesi, 2600 Douglas Road, Suite 700, Coral Gables, Florida 33134, Miamivivasico@ec: B.Com, “ w | i. MAJID OSSOUGpilIN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CIVIL DIVISION CASE # 19-000629 CC 26 MULTIMED CARE, INC. AIAIO ARACELYS LEYVA, Plaintiff, v. GEICO GENERAL INSURANCE COMPANY, Defendant. / ORDER ON PLAINTIFF'S EX-PARTE MOTION TO COMPEL DISCOVERY (Expert interrogatories) THIS CAUSE having come before the court upon Plaintiffs Ex-Parte Motion to Compel Discovery, and the Court having considered same, it is hereby; ORDERED AND ADJUDGED that Plaintiff's Ex-Parte Motion to Compel Discovery is hereby GRANTED. Defendant shall have ten (10) days from the date of this Order to respond to Plaintiff's Expert Interrogatories. Failure to comply with this order may result in an appropriate order as enumerated under Florida Rules of Civil procedure 1.380(b)(2). DONE AND ORDERED in chambers, at Miami-Dade County, Florida, this day of » 2019. Copies furnished to: COUNTY COURT JUDGE Counsel of Record