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Filing # 61675276 E-Filed 09/18/2017 09:05:33 PM
IN THE CIRCUIT COURT OF THE
11™ JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
NAKIA HILL, as Personal Representative
of the ESTATE OF
ALPHONSO MCCLAIN, JR.,
GENERAL JURISDICTION DIVISION
Plaintiff,
Vs. CASE NO.:2017-013631-CA-01
THE URBAN LEAGUE OF GREATER MIAMI, INC.,
THE URBAN LEAGUE HOUSING CORPORATION
OF GREATER MIAMI, INC., AND THE URBAN
LEAGUE HOUSING PARTNER, INC.,
Defendants.
/
DEFENDANTS’, THE URBAN LEAGUE OF GREATER MIAMI, INC. AND THE URBAN LEAGUE
HOUSING PARTNER, INC., MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S
FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION
Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE URBAN LEAGUE HOUSING
PARTNER, INC., pursuant to Fla. R. Civ. P. Rule 1.090(b), hereby move this Court for an
enlargement of time to respond to Plaintiff's, NAKIA HILL, as Personal Representative of the
ESTATE OF ALPHONSO MCCLAIN, JR., First Set of Interrogatories and Request For Production,
which were served contemporaneously with the Complaint and Summons in June 2017:
1. In June 2017, Plaintiff served its First Set of Interrogatories and Request For Production
to the Registered Agent for the Defendants, contemporaneously with the Summons and
Complaint, which Defendants' Registered Agent had apparently misplaced.
2. On August 3, 2017, parties agreed to 20 days to file an answer to the Complaint, which
was then timely filed, but parties did not address the past due discovery.
1of33. On August 31, 2017, as a courtesy, Plaintiff provided the undersigned counsel with a copy
of the interrogatories and undersigned counsel procured a copy of the request for
production. The undersigned counsel was also in the process of procuring and reviewing
insurance policies on each of the defendants to determine coverage and whether
insurance defense counsel would consequently make an appearance to address the
discovery.
4. Insurance defense counsel subsequently made an appearance on behalf of one
Defendant, The Urban League Housing Corporation of Greater Miami, Inc. An extension
of time to respond to discovery was agreed between its insurance counsel and Plaintiff.
5. On behalf of the two remaining defendants, the undersigned counsel is requesting
additional time of twenty (20) days from the date of this Motion's filing to accurately
respond to the above-mentioned written discovery at this time. Undersigned counsel will
confer with Plaintiff counsel to attempt to come to an agreement.
6. This request is not made for the purpose of any delay, harassment, or improper purpose
and the requested enlargement of time would not prejudice the Plaintiff.
WHEREFORE, the Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE URBAN
LEAGUE HOUSING PARTNER, INC., pursuant to Fla. R. Civ. P. Rule 1.090(b), respectfully
requests an enlargement of time of twenty (20) days from the date of this Motion's filing to
serve answers and responses to Plaintiff's, NAKIA HILL, as Personal Representative of the
ESTATE OF ALPHONSO MCCLAIN, JR., First Set of Interrogatories and Request For Production,
and for such other and further relief this Court deems just and proper.
2of3CERTIFICATE OF SERVICE
| HEREBY CERTIFY that on this 18th day of September 2017, a true and correct copy of the
foregoing was emailed to the following parties, via the Florida Courts e-Filing Portal, and by
e-courtesy, to the following: Richard B. Sharp, Esq., Mallard & Sharp, P.A.,
bo@msiaweenter.com; rocio@m er.com; 7700 N. Kendall Dr., Ste.303, Miami, FL
33156, Attorney for Plaintiff, Nakia Hill, and to Benjamin Esco, Esq., Cole, Scott & Kissane,
P.A., ban.esco@eskiegal.com; nina.conte@csklegal.com; 9150 S. Dadeland Blvd., Ste.1400,
Miami, FL 33256, Attorney for Defendant, The Urban League Housing Corporation of Greater
Miami, Inc.
fsf: Eugene 3. La Neve
Eugene J. La Neve, Esq.
FLA. BAR 381720
LAW FIRM OF EUGENE J. La NEVE, P.A.
Counsel for Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE
URBAN LEAGUE HOUSING PARTNER, INC.
Datran Center . Suite 1500
9100 S. Dadeland Blvd.
Miami, Florida 33156
(786) 910-5262
awfirm.corn
3o0f3
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Filing # 61675276 E-Filed 09/18/2017 09:05:33 PM IN THE CIRCUIT COURT OF THE 11™ JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA NAKIA HILL, as Personal Representative of the ESTATE OF ALPHONSO MCCLAIN, JR., GENERAL JURISDICTION DIVISION Plaintiff, Vs. CASE NO.:2017-013631-CA-01 THE URBAN LEAGUE OF GREATER MIAMI, INC., THE URBAN LEAGUE HOUSING CORPORATION OF GREATER MIAMI, INC., AND THE URBAN LEAGUE HOUSING PARTNER, INC., Defendants. / DEFENDANTS’, THE URBAN LEAGUE OF GREATER MIAMI, INC. AND THE URBAN LEAGUE HOUSING PARTNER, INC., MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S FIRST SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE URBAN LEAGUE HOUSING PARTNER, INC., pursuant to Fla. R. Civ. P. Rule 1.090(b), hereby move this Court for an enlargement of time to respond to Plaintiff's, NAKIA HILL, as Personal Representative of the ESTATE OF ALPHONSO MCCLAIN, JR., First Set of Interrogatories and Request For Production, which were served contemporaneously with the Complaint and Summons in June 2017: 1. In June 2017, Plaintiff served its First Set of Interrogatories and Request For Production to the Registered Agent for the Defendants, contemporaneously with the Summons and Complaint, which Defendants' Registered Agent had apparently misplaced. 2. On August 3, 2017, parties agreed to 20 days to file an answer to the Complaint, which was then timely filed, but parties did not address the past due discovery. 1of33. On August 31, 2017, as a courtesy, Plaintiff provided the undersigned counsel with a copy of the interrogatories and undersigned counsel procured a copy of the request for production. The undersigned counsel was also in the process of procuring and reviewing insurance policies on each of the defendants to determine coverage and whether insurance defense counsel would consequently make an appearance to address the discovery. 4. Insurance defense counsel subsequently made an appearance on behalf of one Defendant, The Urban League Housing Corporation of Greater Miami, Inc. An extension of time to respond to discovery was agreed between its insurance counsel and Plaintiff. 5. On behalf of the two remaining defendants, the undersigned counsel is requesting additional time of twenty (20) days from the date of this Motion's filing to accurately respond to the above-mentioned written discovery at this time. Undersigned counsel will confer with Plaintiff counsel to attempt to come to an agreement. 6. This request is not made for the purpose of any delay, harassment, or improper purpose and the requested enlargement of time would not prejudice the Plaintiff. WHEREFORE, the Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE URBAN LEAGUE HOUSING PARTNER, INC., pursuant to Fla. R. Civ. P. Rule 1.090(b), respectfully requests an enlargement of time of twenty (20) days from the date of this Motion's filing to serve answers and responses to Plaintiff's, NAKIA HILL, as Personal Representative of the ESTATE OF ALPHONSO MCCLAIN, JR., First Set of Interrogatories and Request For Production, and for such other and further relief this Court deems just and proper. 2of3CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 18th day of September 2017, a true and correct copy of the foregoing was emailed to the following parties, via the Florida Courts e-Filing Portal, and by e-courtesy, to the following: Richard B. Sharp, Esq., Mallard & Sharp, P.A., bo@msiaweenter.com; rocio@m er.com; 7700 N. Kendall Dr., Ste.303, Miami, FL 33156, Attorney for Plaintiff, Nakia Hill, and to Benjamin Esco, Esq., Cole, Scott & Kissane, P.A., ban.esco@eskiegal.com; nina.conte@csklegal.com; 9150 S. Dadeland Blvd., Ste.1400, Miami, FL 33256, Attorney for Defendant, The Urban League Housing Corporation of Greater Miami, Inc. fsf: Eugene 3. La Neve Eugene J. La Neve, Esq. FLA. BAR 381720 LAW FIRM OF EUGENE J. La NEVE, P.A. Counsel for Defendants, THE URBAN LEAGUE OF GREATER MIAMI, INC. and THE URBAN LEAGUE HOUSING PARTNER, INC. Datran Center . Suite 1500 9100 S. Dadeland Blvd. Miami, Florida 33156 (786) 910-5262 awfirm.corn 3o0f3