On October 16, 2020 a
Motion for Extension of Time - TO RESPOND TO PLAINTIFF'S COMPLAINTParty: Defendant Universal Property and Casualty Insurance Company
was filed
involving a dispute between
Nguyen, Hoa,
Pennington, Teresa,
and
Universal Property And Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 117303116 E-Filed 11/25/2020 06:55:39 PM
IN THE CIRCUIT COURT OF THE 17'!
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
HOA NGUYEN AND TERESA
PENNINGTON CASE NO.: CACE-20-017251
Plaintiff(s),
vs.
UNIVERSAL PROPERTY AND CASUALTY
INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND
TO PLAINTIFF’S COMPLAINT
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
(‘Universal’), by and through the undersigned counsel, hereby files its Motion for Extension of
Time to Respond to Plaintiff's Complaint, and states as follows:
1. This matter arises out of a claim asserted by Plaintiff against Universal for damages
arising out of and resulting from a purported covered loss alleged in Plaintiff's Complaint.
2. The undersigned counsel is in receipt of Plaintiff's Complaint; however, additional
time is necessary to respond and as such, Universal would respectfully request additional time to
review the file, discuss early resolution, and if necessary, file a response to Plaintiff's Complaint.
3. Defendant is requesting an extension of thirty (30) days.
4. This Motion is not being filed for the purposes of undue delay and will not prejudice
any party.
WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests
this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to
Plaintiff's Complaint and any and all other relief this Court may deem just and proper.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/25/2020 06:55:40 PM.****Page 2 of 2
_CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
Electronic Service to: Kevin Weisser, Esq., (KW@WEKLaw.com; PB@WEKLaw.com), counsel
for Plaintiff, on this 25" day of November 2020.
Attorney for Defendant
Universal Property & Casualty Ins. Co.
P.O. Box 9388
Fort Lauderdale, FL 33310
Telephone: 954-958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: 954-958-1262
By:_/s/ Ryan Taub, Esq.
Ryan Taub, Esquire
Florida Bar No. 112213
For Service of Court Documents only:
Primary:upciceservice04@universalproperty.com
Secondary: KL1110@universalproperty.com
Tertiary: RT0604@universalproperty.com
For Scheduling Matters:
KL1110@universalproperty.com
*Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com
or upciceservice04@universalproperty.com.
Document Filed Date
November 25, 2020
Case Filing Date
October 16, 2020
Category
Contract and Indebtedness
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Filing # 117303116 E-Filed 11/25/2020 06:55:39 PM IN THE CIRCUIT COURT OF THE 17'! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA HOA NGUYEN AND TERESA PENNINGTON CASE NO.: CACE-20-017251 Plaintiff(s), vs. UNIVERSAL PROPERTY AND CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY (‘Universal’), by and through the undersigned counsel, hereby files its Motion for Extension of Time to Respond to Plaintiff's Complaint, and states as follows: 1. This matter arises out of a claim asserted by Plaintiff against Universal for damages arising out of and resulting from a purported covered loss alleged in Plaintiff's Complaint. 2. The undersigned counsel is in receipt of Plaintiff's Complaint; however, additional time is necessary to respond and as such, Universal would respectfully request additional time to review the file, discuss early resolution, and if necessary, file a response to Plaintiff's Complaint. 3. Defendant is requesting an extension of thirty (30) days. 4. This Motion is not being filed for the purposes of undue delay and will not prejudice any party. WHEREFORE, Universal Property and Casualty Insurance Company respectfully requests this Court to enter an Order Granting Defendant an additional thirty (30) days to respond to Plaintiff's Complaint and any and all other relief this Court may deem just and proper. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/25/2020 06:55:40 PM.****Page 2 of 2 _CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Electronic Service to: Kevin Weisser, Esq., (KW@WEKLaw.com; PB@WEKLaw.com), counsel for Plaintiff, on this 25" day of November 2020. Attorney for Defendant Universal Property & Casualty Ins. Co. P.O. Box 9388 Fort Lauderdale, FL 33310 Telephone: 954-958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: 954-958-1262 By:_/s/ Ryan Taub, Esq. Ryan Taub, Esquire Florida Bar No. 112213 For Service of Court Documents only: Primary:upciceservice04@universalproperty.com Secondary: KL1110@universalproperty.com Tertiary: RT0604@universalproperty.com For Scheduling Matters: KL1110@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice04@universalproperty.com.