On June 03, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Citizens Property Insurance Corporation,
and
Total Care Restoration, Llc,
for Declaratory Judgment
in the District Court of Miami-Dade County.
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Filing # 58506523 E-Filed 06/30/2017 02:29:23 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL
CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA
CITIZENS PROPERTY INSURANCE CORPORATION,
Plaintiff,
vs. CASE NO. 2017-013318-CA-01
TOTAL CARE RESTORATION LLC
a/alo MIGUEL MONTALVO
Defendant.
/
Defendant’s Motion for Extension of Time to Respond to Plaintiff
Defendant, TOTAL CARE RESTORATION, LLC a/a/o MIGUEL MONTALVO (“Total
Care”), files this Motion for an Extension of Time to Respond to Plaintiff, CITIZENS
PROPERTY INSURANCE CORPORATION’s (the “Insurance Company”), Complaint,
and states:
1. The Insurance Company filed suit against Total Care for specific performance and
declaratory relief.
2. Pursuant to the applicable Rules of Civil Procedure, Total Care's response to the
Complaint was due June 28, 2017
3. Total Care respectfully seeks an extension of time to respond to the Insurance
Company’s Complaint
4. The undersigned attorneys contacted counsel for the Insurance Company on June
28, 2017 to discuss the matter and request an extension of time to respond.
5. The requested extension is not made for purposes of delay, and no party will be
prejudiced by the extension.
WHEREFORE, Defendant, TOTAL CARE RESTORATION, LLC a/a/o
MIGUEL MONTALVO, respectfully requests an extension of time of twenty days to
respond to the Complaint in this matter, making the first responsive pleading due on or
before July 18, 2017.CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy of the foregoing was furnished via e-Service this
27" day of June, 2017 to: Eric J. Knuth, Esq. attorney at VERNIS &BOWLING of
MIAMI, PA, 1680 NE 135 Street Miami, FL 33181, Email eknuth@florida-law.com and
cknuthfiling@florida-law.com
Pagan & Stroleny, P.L.
One NE 2™ Avenue
Suite 200
Miami, Florida 33132
Tel: (305) 615-1285
Esther@pslaw.org
FL Bar No. 91950
/s/ Esther Alcaraz
Esther Alcaraz, Esq.
Document Filed Date
June 30, 2017
Case Filing Date
June 03, 2017
Category
Declaratory Judgment
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Filing # 58506523 E-Filed 06/30/2017 02:29:23 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CITIZENS PROPERTY INSURANCE CORPORATION, Plaintiff, vs. CASE NO. 2017-013318-CA-01 TOTAL CARE RESTORATION LLC a/alo MIGUEL MONTALVO Defendant. / Defendant’s Motion for Extension of Time to Respond to Plaintiff Defendant, TOTAL CARE RESTORATION, LLC a/a/o MIGUEL MONTALVO (“Total Care”), files this Motion for an Extension of Time to Respond to Plaintiff, CITIZENS PROPERTY INSURANCE CORPORATION’s (the “Insurance Company”), Complaint, and states: 1. The Insurance Company filed suit against Total Care for specific performance and declaratory relief. 2. Pursuant to the applicable Rules of Civil Procedure, Total Care's response to the Complaint was due June 28, 2017 3. Total Care respectfully seeks an extension of time to respond to the Insurance Company’s Complaint 4. The undersigned attorneys contacted counsel for the Insurance Company on June 28, 2017 to discuss the matter and request an extension of time to respond. 5. The requested extension is not made for purposes of delay, and no party will be prejudiced by the extension. WHEREFORE, Defendant, TOTAL CARE RESTORATION, LLC a/a/o MIGUEL MONTALVO, respectfully requests an extension of time of twenty days to respond to the Complaint in this matter, making the first responsive pleading due on or before July 18, 2017.CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy of the foregoing was furnished via e-Service this 27" day of June, 2017 to: Eric J. Knuth, Esq. attorney at VERNIS &BOWLING of MIAMI, PA, 1680 NE 135 Street Miami, FL 33181, Email eknuth@florida-law.com and cknuthfiling@florida-law.com Pagan & Stroleny, P.L. One NE 2™ Avenue Suite 200 Miami, Florida 33132 Tel: (305) 615-1285 Esther@pslaw.org FL Bar No. 91950 /s/ Esther Alcaraz Esther Alcaraz, Esq.