On June 23, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Mazel Medical Center Inc,
and
United Automobile Insurance Company,
for Personal Injury Protection ($8,001 - $15,000)
in the District Court of Miami-Dade County.
Preview
Filing # 132047715 E-Filed 08/04/2021 03:49:53 PM
MAZEL MEDICAL CENTER INC a/a/o IN THE COUNTY COURT IN AND
LEON D. MORENO FOR MIAMI-DADE COUNTY,
FLORIDA
Plaintiff,
vs. CIVIL DIVISION
CASE NO: 21-020900 CC 26 (05)
UNITED AUTOMOBILE INSURANCE
COMPANY, a Florida Corporation FL BAR No. 15336
Defendant
/
DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendant, UNITED AUTOMOBILE INSURANCE COMPANY (“United
Auto”), pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure, moves for an
enlargement of time within which to respond to Plaintiff’s Complaint. In support of this
motion, United Auto states as follows:
1. This is an action for personal injury protection (“PIP”) benefits under
Florida’s Motor Vehicle No-Fault law.
2. Plaintiff has served United Auto with the Complaint for the instant action.
3. Undersigned counsel fairly needs a sixty (60) day enlargement of time to
confer with the client, to obtain and review the necessary documents and to otherwise
respond to Plaintiff’s Complaint.
4. Undersigned counsel has not previously sought an enlargement of time in
this case, and this motion is made in good faith and not for purposes of delay.
5. In addition, as the time for responding to Plaintiff’s Complaint has not yet
expired, Florida Rule of Civil Procedure 1.090 (b) authorizes this court to grant the
requested enlargement of time without notice.
WHEREFORE, Defendant, United Automobile Insurance Company, respectfully
requests the entry of an order allowing it an additional sixty (60) days within which to
respond to Plaintiff’s Complaint.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
E-Mail on August 4, 2021 to Yulexy Solis, Esq. at ANDREU, PALMA, LAVIN & SOLIS,
PLLC / pleadings4@andreupalma.com, 815 NW 57th Avenue, Suite 401, Miami, FL
33126.
House Counsel of
United Automobile Insurance Company
Attorneys for the Defendant
P.O BOX 694260
Miami, FL 33269-9854
E-Mail: HC_Service@uaig.net
Phone (305) 774-6160
/s/ Andrea Harris
BY: _______________________
Andrea Harris, Esq.
FL BAR No. 15336
Document Filed Date
August 04, 2021
Case Filing Date
June 23, 2021
Category
Personal Injury Protection ($8,001 - $15,000)
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Filing # 132047715 E-Filed 08/04/2021 03:49:53 PM MAZEL MEDICAL CENTER INC a/a/o IN THE COUNTY COURT IN AND LEON D. MORENO FOR MIAMI-DADE COUNTY, FLORIDA Plaintiff, vs. CIVIL DIVISION CASE NO: 21-020900 CC 26 (05) UNITED AUTOMOBILE INSURANCE COMPANY, a Florida Corporation FL BAR No. 15336 Defendant / DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendant, UNITED AUTOMOBILE INSURANCE COMPANY (“United Auto”), pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure, moves for an enlargement of time within which to respond to Plaintiff’s Complaint. In support of this motion, United Auto states as follows: 1. This is an action for personal injury protection (“PIP”) benefits under Florida’s Motor Vehicle No-Fault law. 2. Plaintiff has served United Auto with the Complaint for the instant action. 3. Undersigned counsel fairly needs a sixty (60) day enlargement of time to confer with the client, to obtain and review the necessary documents and to otherwise respond to Plaintiff’s Complaint. 4. Undersigned counsel has not previously sought an enlargement of time in this case, and this motion is made in good faith and not for purposes of delay. 5. In addition, as the time for responding to Plaintiff’s Complaint has not yet expired, Florida Rule of Civil Procedure 1.090 (b) authorizes this court to grant the requested enlargement of time without notice. WHEREFORE, Defendant, United Automobile Insurance Company, respectfully requests the entry of an order allowing it an additional sixty (60) days within which to respond to Plaintiff’s Complaint. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Mail on August 4, 2021 to Yulexy Solis, Esq. at ANDREU, PALMA, LAVIN & SOLIS, PLLC / pleadings4@andreupalma.com, 815 NW 57th Avenue, Suite 401, Miami, FL 33126. House Counsel of United Automobile Insurance Company Attorneys for the Defendant P.O BOX 694260 Miami, FL 33269-9854 E-Mail: HC_Service@uaig.net Phone (305) 774-6160 /s/ Andrea Harris BY: _______________________ Andrea Harris, Esq. FL BAR No. 15336