On June 23, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Rodriguez, Imiris,
and
Olympus Insurance Company,
for Contract & Indebtedness
in the District Court of Miami-Dade County.
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Filing # 61972906 E-Filed 09/25/2017 06:53:44 PM
101.0704
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO: 2017-015158-CA-01
IMIRIS RODRIGUEZ,
Plaintiff,
Vv.
OLYMPUS INSURANCE COMPANY,
Defendant
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S DISCOVERY
COMES NOW, Defendant, OLYMPUS INSURANCE COMPANY (“OLYMPUS”), by
and through the undersigned counsel, and hereby files this, its Motion for Extension of Time to
Respond to Discovery, and in support thereof states as follows:
1 Plaintiff commenced this action with a Complaint for breach of contract.
2. OLYMPUS was served with discovery, making its responses due on or before
September 25, 2017
3. OLYMPUS requires additional time to prepare its responses/objections to
Plaintiff’ s Interrogatories, Request for Admissions, and Request to Produce.
4. OLYMPUS hereby requests an additional twenty (20) days to serve its responses
and objections to Plaintiff’ s Interrogatories, Request for Admissions, and Request to Produce.
5. This Motion is not brought for purposes of delay, and the granting of this Motion
will not unfairly prejudice any party:CASE NO: 2017-015158-CA-01
MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY
WHEREFORE, for the foregoing reasons, OLYMPUS INSURANCE COMPANY
respectfully requests an extension of twenty (20) days to serve its responses/objections to
Plaintiff's Interrogatories, Request for Admissions, and Request to Produce, along with any other
relief this Court deems just and proper.
CERTIFICATE OF SERVICE
I certify that a copy of the foregoing document has been furnished to: Adry Polo,
Esquire, Gimenez & Carrillo, LLC, 7380 West Sand Lake Road, Suite 500, Orlando, FL 32819,
via e-Service through the Florida Courts e-filing Portal, on this 25" day of September, 2017
Respectfully submitted,
GUTTERMAN TRIAL GROUP
Attorneys for OLYMPUS INSURANCE COMPANY
200 East Broward Boulevard, Suite 1630
Fort Lauderdale, Florida 33301
Telephone: 754.218.8255
Facsimile: 754.218.8259
Primary Eservice: eservice@guttermangroup.com
By /s/ Kalpesh Mehta
Marc J. Gutterman, Esquire
Florida Bar No.: 118818
Secondary Eservice: mgutterman@guttermangroup.com
Kalpesh Mehta, Esquire
Florida Bar No.: 121882
Secondary Eservice: kmehta@guttermangroup.comCASE NO: 2017-015158-CA-01
MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY
Document Filed Date
September 25, 2017
Case Filing Date
June 23, 2017
Category
Contract & Indebtedness
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Filing # 61972906 E-Filed 09/25/2017 06:53:44 PM 101.0704 IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NO: 2017-015158-CA-01 IMIRIS RODRIGUEZ, Plaintiff, Vv. OLYMPUS INSURANCE COMPANY, Defendant / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S DISCOVERY COMES NOW, Defendant, OLYMPUS INSURANCE COMPANY (“OLYMPUS”), by and through the undersigned counsel, and hereby files this, its Motion for Extension of Time to Respond to Discovery, and in support thereof states as follows: 1 Plaintiff commenced this action with a Complaint for breach of contract. 2. OLYMPUS was served with discovery, making its responses due on or before September 25, 2017 3. OLYMPUS requires additional time to prepare its responses/objections to Plaintiff’ s Interrogatories, Request for Admissions, and Request to Produce. 4. OLYMPUS hereby requests an additional twenty (20) days to serve its responses and objections to Plaintiff’ s Interrogatories, Request for Admissions, and Request to Produce. 5. This Motion is not brought for purposes of delay, and the granting of this Motion will not unfairly prejudice any party:CASE NO: 2017-015158-CA-01 MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY WHEREFORE, for the foregoing reasons, OLYMPUS INSURANCE COMPANY respectfully requests an extension of twenty (20) days to serve its responses/objections to Plaintiff's Interrogatories, Request for Admissions, and Request to Produce, along with any other relief this Court deems just and proper. CERTIFICATE OF SERVICE I certify that a copy of the foregoing document has been furnished to: Adry Polo, Esquire, Gimenez & Carrillo, LLC, 7380 West Sand Lake Road, Suite 500, Orlando, FL 32819, via e-Service through the Florida Courts e-filing Portal, on this 25" day of September, 2017 Respectfully submitted, GUTTERMAN TRIAL GROUP Attorneys for OLYMPUS INSURANCE COMPANY 200 East Broward Boulevard, Suite 1630 Fort Lauderdale, Florida 33301 Telephone: 754.218.8255 Facsimile: 754.218.8259 Primary Eservice: eservice@guttermangroup.com By /s/ Kalpesh Mehta Marc J. Gutterman, Esquire Florida Bar No.: 118818 Secondary Eservice: mgutterman@guttermangroup.com Kalpesh Mehta, Esquire Florida Bar No.: 121882 Secondary Eservice: kmehta@guttermangroup.comCASE NO: 2017-015158-CA-01 MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY