On October 22, 2020 a
Motion for Extension of Time - SECONDParty: Defendant Universal Property & Casualty Insurance Company
was filed
involving a dispute between
Lewis Dixon, Camala,
and
Universal Property & Casualty Insurance Company,
for Contract and Indebtedness
in the District Court of Broward County.
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Filing # 119195918 E-Filed 01/07/2021 08:36:51 AM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA.
CAMALA LEWIS DIXON, CASE NO.: CACE-20-017636
Plaintiff,
vs.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF’S COMPLAINT AND DISCOVERY REQUESTS SERVED
WITH THE SUMMONS AND COMP! T
Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY
(“Universal”), by and through the undersigned counsel, hereby files its Second Motion for
Extension of Time to Respond to Plaintiff's Complaint and Discovery Requests served with the
Summons and Complaint, and states as follows:
1. This matter arises out of a claim asserted by CAMALA LEWIS DIXON (“Plaintiff”)
against Universal for damages arising out of and resulting from alleged damage occurring on
September 10, 2017.
2. The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery
Requests, however, additional time is necessary to respond and as such, Universal would
respectfully requests an additional thirty (30) days from the date of this Motion to review the file,
discuss early resolution, and if necessary, file a responsive pleading to Plaintiff's Complaint and
an additional twenty (20) days thereafter to respond to Plaintiff's Discovery Requests.
3. This Motion is not being filed for the purposes of delay and will not prejudice any
party.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/07/2021 08:36:51 AM.****CACE-20-017636
Page 2 of 2
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 an additional twenty (20) days thereafter to respond to Plaintiff's
Discovery Requests.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E-
Service to: Kevin Weisser, Esq. (kw@weklaw.com; pb@weklaw.com) on January 7, 2021.
Attorney for Defendant
Universal Property & Casualty Insurance Company
P.O. Box 9388
Fort Lauderdale, Florida 33309
Telephone: (954) 958-3319
Toll-Free: 1-833-658-8594 (Judges Only)
Facsimile: (954) 958-1262
By: /s/Alina Maria Alvarez
Alina Maria Alvarez, Esq.
Florida Bar No. 127087
For Service of Court Documents only:
Primary: upciceservice02@universalproperty.com
Secondary: sr0327@universalproperty.com
Tertiary: aj0709@universalproperty.com
For Scheduling Matters:
sr0327@universalproperty.com
*Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com
or upciceservice02@universalproperty.com.
Document Filed Date
January 07, 2021
Case Filing Date
October 22, 2020
Category
Contract and Indebtedness
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Filing # 119195918 E-Filed 01/07/2021 08:36:51 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. CAMALA LEWIS DIXON, CASE NO.: CACE-20-017636 Plaintiff, vs. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / SECOND MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT AND DISCOVERY REQUESTS SERVED WITH THE SUMMONS AND COMP! T Defendant, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY (“Universal”), by and through the undersigned counsel, hereby files its Second Motion for Extension of Time to Respond to Plaintiff's Complaint and Discovery Requests served with the Summons and Complaint, and states as follows: 1. This matter arises out of a claim asserted by CAMALA LEWIS DIXON (“Plaintiff”) against Universal for damages arising out of and resulting from alleged damage occurring on September 10, 2017. 2. The undersigned counsel is in receipt of Plaintiff's Complaint and Discovery Requests, however, additional time is necessary to respond and as such, Universal would respectfully requests an additional thirty (30) days from the date of this Motion to review the file, discuss early resolution, and if necessary, file a responsive pleading to Plaintiff's Complaint and an additional twenty (20) days thereafter to respond to Plaintiff's Discovery Requests. 3. This Motion is not being filed for the purposes of delay and will not prejudice any party. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/07/2021 08:36:51 AM.****CACE-20-017636 Page 2 of 2 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 an additional twenty (20) days thereafter to respond to Plaintiff's Discovery Requests. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via E- Service to: Kevin Weisser, Esq. (kw@weklaw.com; pb@weklaw.com) on January 7, 2021. Attorney for Defendant Universal Property & Casualty Insurance Company P.O. Box 9388 Fort Lauderdale, Florida 33309 Telephone: (954) 958-3319 Toll-Free: 1-833-658-8594 (Judges Only) Facsimile: (954) 958-1262 By: /s/Alina Maria Alvarez Alina Maria Alvarez, Esq. Florida Bar No. 127087 For Service of Court Documents only: Primary: upciceservice02@universalproperty.com Secondary: sr0327@universalproperty.com Tertiary: aj0709@universalproperty.com For Scheduling Matters: sr0327@universalproperty.com *Please do not send any inquiries or scheduling matters to upciceservice@universalproperty.com or upciceservice02@universalproperty.com.