On October 22, 2020 a
Motion for Extension of Time - Party: Defendant Omega Insurance Company
was filed
involving a dispute between
Hedge, Jean,
Hedge, Robert,
and
Omega Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 118776519 E-Filed 12/28/2020 03:08:32 PM
IN THE CIRCUIT COURT FOR THE 17™
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE-20-017607
JEAN HEDGE AND
ROBERT HEDGE,
Plaintiffs,
vs.
OMEGA INSURANCE COMPANY,
Defendant.
(Sees See e eee eee e eee eeee esse seeeer
DEFENDANT, OMEGA INSURANCE COMPANY'S MOTION FOR EXTENSION OF
TIME TO RESPOND AND OBJECT TO PLAINTIFFS’ DISCOVERY
Defendant, OMEGA INSURANCE COMPANY ("Omega"), by and through its
undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090, respectfully moves
for an extension of time within which to respond and object to Plaintiffs’ Discovery Requests,
and as grounds thereof would state as follows:
lL. Plaintiffs, JEAN HEDGE AND ROBERT HEDGE, served their First
Interrogatories and Request for Production (“Discovery Requests”) along with the Complaint on
Omega on November 13, 2020.
2. Counsel for Omega requires additional time in order to adequately provide its
responses and objections to Plaintiffs’ Discovery Requests.
3. Omega requests this Court issue an Order extending the time period for
responding and objecting to the Discovery Requests for thirty (30) days
4. This motion is not intended to harass or prejudice the Plaintiffs’ in anyway, nor is
it used for the purpose of undue hindrance or delay.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/28/2020 03:08:32 PM.****5. Florida Rule of Civil Procedure 1.090(b) allows this Court to extend the time in
which Omega has to respond and object to Plaintiffs’ Discovery Requests.
WHEREFORE, Defendant, OMEGA INSURANCE COMPANY, respectfully requests
an extension of time to respond and object to Plaintiffs’ Interrogatories and Request for
Production.
By
Primary
Primary
Secondary
Attorneys for
Respectfully Submitted,
MARSHALL DENNEHEY
WARNER COLEMAN & GOGGIN
/s/Isabel Andreacchi
Danielle N. Robinson
Florida Bar Number: 13921
dnrobinson@mdweg.com
Isabel Andreacchi
Florida Bar Number: 92906
iiandreacchi@mdweg.com
2400 E. Commercial Blvd.,
Suite 1100
Fort Lauderdale, FL 33308
Phone: (954) 847-4920
mjgagliardo@mdweg.com
trvalentin@mdweg.com
pleadingsft|@mdweg.com
OMEGA INSURANCE COMPANY
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the foregoing Motion for Extension of
Time was sent by electronic mail this 28 day of December 2020, to Peter Mineo, Jr., Esq., The
Mineo Salcedo Law Firm, P.A., 5600 Davie Road, Davie, Fl. 33314, service@mineolaw.com.
IIA/mjg
s/ Isabel Andreacchi
Isabel Andreacchi, Esq.
Preview
Filing # 118776519 E-Filed 12/28/2020 03:08:32 PM IN THE CIRCUIT COURT FOR THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE-20-017607 JEAN HEDGE AND ROBERT HEDGE, Plaintiffs, vs. OMEGA INSURANCE COMPANY, Defendant. (Sees See e eee eee e eee eeee esse seeeer DEFENDANT, OMEGA INSURANCE COMPANY'S MOTION FOR EXTENSION OF TIME TO RESPOND AND OBJECT TO PLAINTIFFS’ DISCOVERY Defendant, OMEGA INSURANCE COMPANY ("Omega"), by and through its undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.090, respectfully moves for an extension of time within which to respond and object to Plaintiffs’ Discovery Requests, and as grounds thereof would state as follows: lL. Plaintiffs, JEAN HEDGE AND ROBERT HEDGE, served their First Interrogatories and Request for Production (“Discovery Requests”) along with the Complaint on Omega on November 13, 2020. 2. Counsel for Omega requires additional time in order to adequately provide its responses and objections to Plaintiffs’ Discovery Requests. 3. Omega requests this Court issue an Order extending the time period for responding and objecting to the Discovery Requests for thirty (30) days 4. This motion is not intended to harass or prejudice the Plaintiffs’ in anyway, nor is it used for the purpose of undue hindrance or delay. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/28/2020 03:08:32 PM.****5. Florida Rule of Civil Procedure 1.090(b) allows this Court to extend the time in which Omega has to respond and object to Plaintiffs’ Discovery Requests. WHEREFORE, Defendant, OMEGA INSURANCE COMPANY, respectfully requests an extension of time to respond and object to Plaintiffs’ Interrogatories and Request for Production. By Primary Primary Secondary Attorneys for Respectfully Submitted, MARSHALL DENNEHEY WARNER COLEMAN & GOGGIN /s/Isabel Andreacchi Danielle N. Robinson Florida Bar Number: 13921 dnrobinson@mdweg.com Isabel Andreacchi Florida Bar Number: 92906 iiandreacchi@mdweg.com 2400 E. Commercial Blvd., Suite 1100 Fort Lauderdale, FL 33308 Phone: (954) 847-4920 mjgagliardo@mdweg.com trvalentin@mdweg.com pleadingsft|@mdweg.com OMEGA INSURANCE COMPANY CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy of the foregoing Motion for Extension of Time was sent by electronic mail this 28 day of December 2020, to Peter Mineo, Jr., Esq., The Mineo Salcedo Law Firm, P.A., 5600 Davie Road, Davie, Fl. 33314, service@mineolaw.com. IIA/mjg s/ Isabel Andreacchi Isabel Andreacchi, Esq.