Motion for Extension of Time - Party: Defendant Heritage Property And Casualty Insurance Company - Rogenia Handspike Plaintiff vs. Heritage Property And Casualty Insurance Company Defendant

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On October 19, 2020 contract and indebtedness case was filed by Handspike, Rogenia, represented by Garcia, David F, against Heritage Property And Casualty Insurance Company, represented by Kobielush, Kelly L, and Lucero, Lizbell R, in the jurisdiction of Broward County. Judge Frink, Keathan B. presiding.

                        
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                          Filing # 118328842 E-Filed 12/16/2020 03:31:24 PM

IN THE CIRCUIT COURT OF THE 177!
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA

CASE NO.: CACE-20-017305
ROGENIA HANDSPIKE,

Plaintiffs,
Vv.

HERITAGE PROPERTY AND CASUALTY
INSURANCE COMPANY,

Defendant.

MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY

COMES NOW, the Defendant, HERITAGE PROPERTY AND CASUALTY
INSURANCE COMPANY, by and through its undersigned Counsel, and hereby files this Motion
for Extension of Time to Respond to Discovery, in support, states as follows:

1. That the Plaintiff served their discovery, to wit: Interrogatories and Request for
Production on the Defendant.

2. Accordingly, pursuant to the applicable Rules of Civil Procedure, and a prior
extension, Defendant’s responses to the discovery are due on December 31, 2020.

3. The undersigned is not in a position to file a response to the discovery at this time,
and would therefore request an extension of time to January 29, 2021.

4. There should be …