MOTION FOR EXTENSION OF TIME

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                          Filing # 129478856 E-Filed 06/24/2021 08:57:30 PM

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT IN AN FOR PALM
BEACH COUNTY, FLORIDA
FRANCIS ALOYISUS MCMAHON, CASE NO: 2020-CA-010915-XXXX- MB
Plaintiff,

vs.

BMW of NORTH AMERICA, LLC.,

Defendant.

DEFEND. °S MOTION FOR EXTENSI IF TIME TO RESPOND T'
PLA [FF’S INITIAL DI ERY RE!

Defendant, BMW of North America, LLC, (“Defendant”), by and through the undersigned
counsel and pursuant to Rule 1.090(b), Florida Rules of Civil Procedure, hereby files this Motion
for Extension of Time to Respond to Piaintiff’s Requests for Admissions, Interrogatories and
Request to Produce (“initial discovery requests”) and in support thereof, states the following:

1. Plaintiff, Francis Aloyisus McMahon, (“Plaintiff”), caused Defendant to be served
with his initial discovery demands on May 25, 2021.

2. Pursuant to Rules 1.340(a), 1.350(b) and 1.370(a), Florida Rules of Civil Procedure,
Defendant’ s responses to Plaintiff’s initial discovery requests…