On June 30, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Oceania Iv Condominium Association, Inc.,
and
Certain Underwriters At Lloyds, London,
General Security Indemnity Company Of Arizona,
International Insurance Company Of Hannover Se,
Interstate Fire & Casualty Company,
for Insurance Claim
in the District Court of Miami-Dade County.
Preview
Filing # 136675940 E-Filed 10/15/2021 04:35:13 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT, IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
OCEANIA IV CONDOMINIUM
ASSOCIATION, INC.,
Plaintiff,
v.
CERTAIN UNDERWRITERS AT LLOYD'S, CASE NO. 2021-015900-CA-01
LONDON; INTERNATIONAL INSURANCE
COMPANY OF HANNOVER SE; GENERAL
SECURITY INDEMNITY COMPANY OF
ARIZONA; and INTERSTATE FIRE &
CASUAL COMPANY,
Defendants.
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY
REQUESTS
COMES NOW, the Defendants, CERTAIN INTERESTED UNDERWRITERS AT
LLOYD'S, LONDON, SUBSCRIBING TO POLICY NUMBER AOP-170262 and AQS-1705911,
INTERNATIONAL INSURANCE COMPANY OF HANNOVER SE; GENERAL SECURITY
INDEMNITY COMPANY OF ARIZONA; and INTERSTATE FIRE & CASUALTY
COMPANY, (collectively "Insurers" or "Defendants"), by and through their undersigned counsel,
and hereby files this Motion for Extension of Time to Respond to Plaintiffs' Discovery Requests,
and in support would state as follows:
1. Defendants were served with Plaintiff's First Request to Production ("Discovery
Requests"), along with the Complaint by electronic delivery on August 31, 2021.
1
Plaintiff has incorrectly identified Underwriters in the Complaint. The proper name for Defendants is "Certain
Interested Underwriters at Lloyd's, London, Subscribing to Policy Number AOP-170262 and AQS-170591."
CASE NO. 2021-015900-CA-01
2. Accordingly, Defendants' responses to Plaintiff's Discovery Requests are due on or
before October 15, 2021.
3. At this time, Undersigned counsel needs additional time to review the claim file
materials prior to serving Defendants’ responses to Discovery Requests.
4. This request is made in good faith and is not intended to delay action in this matter.
5. There will be no prejudice to any party by the granting of an enlargement of time
within which to respond to the aforementioned discovery.
WHEREFORE, the Defendants respectfully requests that this Honorable Court enter an
Order granting this motion extending the deadline for the Defendants to file responses to Plaintiff's
First Request for Production and for any further relief it deems just and proper.
Dated: October 15, 2021
Respectfully submitted,
/s/ Melissa V. Jordon
RICHARD M. SINGER, ESQ.
Florida Bar No. 93036
MELISSA V. JORDON, ESQ.
Florida Bar No. 123576
WOOD, SMITH,
HENNING & BERMAN LLP
701 Brickell Avenue, Suite 1640
Miami, Florida 33131
Telephone: (786) 358-6420
Facsimile: (786) 358-6421
rsinger@wshblaw.com
mjordon@wshblaw.com
ccapeles@wshblaw.com
Counsel for Defendants
22559127.1:10679-1395
CASE NO. 2021-015900-CA-01
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this October 15, 2021, a copy of the foregoing was served
via the Florida e-Portal filing system which will send notice to all counsel of record.
/s/ Melissa V. Jordon
MELISSA V. JORDON, ESQ.
22559127.1:10679-1395
Document Filed Date
October 15, 2021
Case Filing Date
June 30, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 136675940 E-Filed 10/15/2021 04:35:13 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMI-DADE COUNTY, FLORIDA OCEANIA IV CONDOMINIUM ASSOCIATION, INC., Plaintiff, v. CERTAIN UNDERWRITERS AT LLOYD'S, CASE NO. 2021-015900-CA-01 LONDON; INTERNATIONAL INSURANCE COMPANY OF HANNOVER SE; GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA; and INTERSTATE FIRE & CASUAL COMPANY, Defendants. MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS COMES NOW, the Defendants, CERTAIN INTERESTED UNDERWRITERS AT LLOYD'S, LONDON, SUBSCRIBING TO POLICY NUMBER AOP-170262 and AQS-1705911, INTERNATIONAL INSURANCE COMPANY OF HANNOVER SE; GENERAL SECURITY INDEMNITY COMPANY OF ARIZONA; and INTERSTATE FIRE & CASUALTY COMPANY, (collectively "Insurers" or "Defendants"), by and through their undersigned counsel, and hereby files this Motion for Extension of Time to Respond to Plaintiffs' Discovery Requests, and in support would state as follows: 1. Defendants were served with Plaintiff's First Request to Production ("Discovery Requests"), along with the Complaint by electronic delivery on August 31, 2021. 1 Plaintiff has incorrectly identified Underwriters in the Complaint. The proper name for Defendants is "Certain Interested Underwriters at Lloyd's, London, Subscribing to Policy Number AOP-170262 and AQS-170591." CASE NO. 2021-015900-CA-01 2. Accordingly, Defendants' responses to Plaintiff's Discovery Requests are due on or before October 15, 2021. 3. At this time, Undersigned counsel needs additional time to review the claim file materials prior to serving Defendants’ responses to Discovery Requests. 4. This request is made in good faith and is not intended to delay action in this matter. 5. There will be no prejudice to any party by the granting of an enlargement of time within which to respond to the aforementioned discovery. WHEREFORE, the Defendants respectfully requests that this Honorable Court enter an Order granting this motion extending the deadline for the Defendants to file responses to Plaintiff's First Request for Production and for any further relief it deems just and proper. Dated: October 15, 2021 Respectfully submitted, /s/ Melissa V. Jordon RICHARD M. SINGER, ESQ. Florida Bar No. 93036 MELISSA V. JORDON, ESQ. Florida Bar No. 123576 WOOD, SMITH, HENNING & BERMAN LLP 701 Brickell Avenue, Suite 1640 Miami, Florida 33131 Telephone: (786) 358-6420 Facsimile: (786) 358-6421 rsinger@wshblaw.com mjordon@wshblaw.com ccapeles@wshblaw.com Counsel for Defendants 22559127.1:10679-1395 CASE NO. 2021-015900-CA-01 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this October 15, 2021, a copy of the foregoing was served via the Florida e-Portal filing system which will send notice to all counsel of record. /s/ Melissa V. Jordon MELISSA V. JORDON, ESQ. 22559127.1:10679-1395