On December 16, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Union Restoration Inc,
and
Edison Insurance Company,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 110201179 E-Filed 07/14/2020 12:06:27 PM
IN THE CIRCUIT COURT OF THE 14THTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CASE NO.:19004524CA
UNION RESTORATION, INC.
(a/a/o Raquel Estrada),
Plaintiff,
vs.
EDISON INSURANCE COMPANY,
Defendant.
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND
TO DEFENDANT’S DISCOVERY REQUESTS
Plaintiff, UNION RESTORATION, INC. by and through their undersigned counsel,
hereby files their Motion for Extension of Time to Respond to Defendant’s Discovery Requests,
and state:
1. This matter arises out of a homeowners’ insurance claim dispute brought by
Plaintiff against Defendant.
2. The undersigned is in receipt of Defendant’s discovery requests, specifically
Defendant’s First Set of Interrogatories and First Request for Production, (hereinafter the
“Discovery Requests”) propounded by the Defendant.
3. Due to scheduling matters and other conflicts, the undersigned respectfully
requests additional time to respond to Defendant’s discovery requests.
4. Florida Rule of Civil Procedure 1.090 (b) states in pertinent part:
(b) Enlargement. When an act is required or allowed to
be done at or within a specified time by order of court,
by these rules, or by notice given thereunder, for cause
shown the court at any time in its discretion (1) with orwithout notice, may order the period enlarged if request
therefore, is made before the expiration of the period
originally prescribed or as extended by a previous order...
5. The Court possesses broad discretion in overseeing discovery and
Protecting parties that come before the Court. See Rojas v. Ryder Truck Rental, Inc., 641 So.2d
855 (Fla. 1994).
6. There is no trial pending in this matter. Further, this motion is not intended
for purposes of delay.
7. The granting of this motion will not prejudice either party.
WHEREFORE, for all of the foregoing reasons, Plaintiff prays that this Court enter an
Order for Enlargement of Time and allow Plaintiff additional time to respond to Defendant’s First
Request for Production and First Interrogatories.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
Email, pursuant to Rule 2.516(b)(1) to: Christopher E. Varner, Esq., CONROY SIMBERG, via
transmission of Notice of Electronic Filing generated by eservice@myficourtaccess.com and/or
was sent by electronic mail to the above addressees, July 14, 2020.
LARRY MOSKOWITZ, P.A.
Attorneys for Plaintiff
400 SE 9" Street
Fort Lauderdale, FL 33316
Telephone: — (954)-797-7990
Facsimile: (954)-333-6254
pleadings@werepresentyou.com
By /s/ Larry Moskowitz
LARRY MOSKOWITZ, ESQ.
Florida Bar No.: 829587
Document Filed Date
July 14, 2020
Case Filing Date
December 16, 2019
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Filing # 110201179 E-Filed 07/14/2020 12:06:27 PM IN THE CIRCUIT COURT OF THE 14THTH JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.:19004524CA UNION RESTORATION, INC. (a/a/o Raquel Estrada), Plaintiff, vs. EDISON INSURANCE COMPANY, Defendant. PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS Plaintiff, UNION RESTORATION, INC. by and through their undersigned counsel, hereby files their Motion for Extension of Time to Respond to Defendant’s Discovery Requests, and state: 1. This matter arises out of a homeowners’ insurance claim dispute brought by Plaintiff against Defendant. 2. The undersigned is in receipt of Defendant’s discovery requests, specifically Defendant’s First Set of Interrogatories and First Request for Production, (hereinafter the “Discovery Requests”) propounded by the Defendant. 3. Due to scheduling matters and other conflicts, the undersigned respectfully requests additional time to respond to Defendant’s discovery requests. 4. Florida Rule of Civil Procedure 1.090 (b) states in pertinent part: (b) Enlargement. When an act is required or allowed to be done at or within a specified time by order of court, by these rules, or by notice given thereunder, for cause shown the court at any time in its discretion (1) with orwithout notice, may order the period enlarged if request therefore, is made before the expiration of the period originally prescribed or as extended by a previous order... 5. The Court possesses broad discretion in overseeing discovery and Protecting parties that come before the Court. See Rojas v. Ryder Truck Rental, Inc., 641 So.2d 855 (Fla. 1994). 6. There is no trial pending in this matter. Further, this motion is not intended for purposes of delay. 7. The granting of this motion will not prejudice either party. WHEREFORE, for all of the foregoing reasons, Plaintiff prays that this Court enter an Order for Enlargement of Time and allow Plaintiff additional time to respond to Defendant’s First Request for Production and First Interrogatories. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via Email, pursuant to Rule 2.516(b)(1) to: Christopher E. Varner, Esq., CONROY SIMBERG, via transmission of Notice of Electronic Filing generated by eservice@myficourtaccess.com and/or was sent by electronic mail to the above addressees, July 14, 2020. LARRY MOSKOWITZ, P.A. Attorneys for Plaintiff 400 SE 9" Street Fort Lauderdale, FL 33316 Telephone: — (954)-797-7990 Facsimile: (954)-333-6254 pleadings@werepresentyou.com By /s/ Larry Moskowitz LARRY MOSKOWITZ, ESQ. Florida Bar No.: 829587