Motion,Ex Parte: Adriana Hincapie, et al Plaintiff vs. Joseph Bernard Wezkiewicz, Jr., et al Defendant

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                                Filing# 137128702 E-Filed 10/22/2021 04:30:40                     PM


                                                                IN  THE CIRCUIT COURT OF THE
                                                                SEVENTEENTH JUDICIAL CIRCUIT IN AND
                                                                FOR BROWARD COUNTY, FLORIDA

        ADRIANA HINCAPIE AND NICOLAS                            CASE NO.. CACE 21-016648            (14)
        HINCAPIE,

               Plaintiffs,
        VS.


        JOSEPH BERNARD WEZKIEWICZ,

               Defendant.
                                                           i



                         DEFENDANT'S MOTION FOR EXTENSION OF TIME TO
                               RESPOND TO PLAINTIFFS' DISCOVERY

               COMES NOW,               the   Defendant,       JOSEPH BERNARD WEZKIEWICZ                    (hereinafter


        "Defendant"),by and through their undersigned attorneys, and moves                   this   Honorable Court for

        an extension of time within which to respond to the discovery propounded by the Plaintiff,


        ADRIANA HINCAPIE AND NICOLAS HINCAPIE                              (hereinafter           and as grounds
                                                                                      "Plaintiffs"),


        thereof,states as follows:

                1.       The   Plaintiff served a set                    First Request for Production and First
                                                        of Interrogatories,


        Request for Admissions to the Defendant with the             initial   Complaint on September 7,2021.

               2.        Pursuant to the Florida Rules of Civil Procedure, the Defendant's responses and


        answers are due on or before October 22,2021.


               3         The undersigned requests an            additional twenty (20) days within     which   to contact


        the Defendant and to discuss proposed responses to the Plaintiff's Interrogatories,
                                                                                         First Request


        for Production   and   First   Request for Admissions.


               WHEREFORE,              the    Defendant,       JOSEPH BERNARD WEZKIEWICZ,                   respectfully

        requests that this Court enter an Order grantingthe Defendant an additional twenty (20) days




          *** FILED:   BROWARD COUNTY,           FL   BRENDA D. FORMAN, CLERK           10/22/2021 04:30:40 PM.****
                                                                   CASE NO- CACE 21-016648                (14)


within which to respond to Plaintiff's Interrogatories,
                                                     and for any and all further relief that this

Honorable Court deems just and proper in the premises.

       I HEREBY CERTIFY that on October 22, 2021, the foregoing was electronically         filed
with the Florida Courts E-FilingPortal and that as a registeredparticipant of the Portal I have
effectuated service through the Portal in compliance with Rule 2.516, Fla. R. Jud. Admin., on
Kevin   Houston,   Esq., khouston@rubensteinlaw.com, emsantana@rubensteinlaw.com,
eservice@rubensteinlaw.com,Rubenstein Law, P.A., 9130 S. Dadeland Blvd, PH, Miami, FL
33156.


                                            NICHOLAS J. RYAN & ASSOCIATES
                                            110 S. E. 6th Street,Suite 2100
                                            Fort Lauderdale, FL 33301

                                            Telephone: (954) 627-9401
                                            E-mail for service (FL R. Jud. Admin. 2.516).
                                            flor.law-shericritelli.2980 19@statefarm.com



                                             Juul.CiADU
                                            Sheri L. Critelli,
                                                             Esq.
                                            Florida Bar No.. 813508

                                            Attorney for Defendant

                                            Attorneys and Staff of Nicholas J.  Ryan &  Associates are Employees
                                            of the   Law   Department of State Farm Mutual Automobile Insurance
                                            Company