On January 19, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Jack Curren,
Nancy Curren,
and
United Property & Casualty Insurance Company,
for CA Contracts and Indebtedness
in the District Court of Lee County.
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Filing # 121366523 E-Filed 02/15/2021 08:50:43 AM
IN THE CIRCUIT COURT OF THE
20TH JUDICIAL CIRCUIT IN AND
FOR LEE COUNTY, FLORIDA
CASE NO.: 21-CA-000403
JACK CURREN AND
NANCY CURREN,
Plaintiffs,
VS.
UNITED PROPERTY & CASUALTY
INSURANCE COMPANY,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFFS’ COMPLAINT
COMES NOW, the Defendant, UNITED PROPERTY & CASUALTY INSURANCE
COMPANY (hereinafter, the “Defendant”), by and through the undersigned counsel and
pursuant to the applicable Florida Rules of Civil Procedure, hereby files this Motion for
Extension of Time to Respond to the Plaintiffs’ Complaint and as grounds in support thereof,
states as follows:
1. Defendant was served with the Complaint on January 26, 2021.
2. The Defendant requires additional time to confer with its counsel, gather the necessary
documents, and formulate proper responses to this Complaint.
3. Defendant hereby requests an extension to prepare a response to the Plaintiffs’
Complaint.
4. This request for an extension will not delay this action and neither party will be
prejudiced by the granting of this motion.
eFiled Lee County Clerk of Courts Page 1CASE NO.: 21-CA-000403
Page 2 of 2
5. The above request for an enlargement of time is asserted in good faith and is not
being filed by the undersigned for purposes of delay.
WHEREFORE, the Defendant, UNITED PROPERTY & CASUALTY INSURANCE
COMPANY, respectfully requests that this Honorable Court enter an Order granting this Motion
for Extension of Time, and for all other relief this Honorable Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed
electronically and was sent by E-mail from the Florida Courts’ E-Filing Portal system, unless
otherwise noted below on this 15" day of February , 2021, on all counsel or parties of record listed
below:
Jared Davis, Esq.
KANNER & PINTALIGA, P.A.
Attorney for Plaintiffs
925 South Federal Highway
Boca Raton, FL 33432
(561) 892-9657 Telephone
(561) 583-2188 Facsimile
jdavis@kpattorney.com
firstpartyeservice@kpattorney.com
CHARTWELL LAW
Attorneys for Defendant
12486 Brantley Commons Court
Fort Myers, FL 33907
(561) 440-5170 Telephone
(239) 425-3509 Facsimile
By: /4s/Amanda M. Bartley
Amanda Bartley, Esq.
Florida Bar: 64979
abartley@chartwelllaw.com
Christopher R. Cooper, Esq.
Florida Bar No. 111434
ccooper@chartwelllaw.com
eFiled Lee County Clerk of Courts Page 2
Document Filed Date
February 15, 2021
Case Filing Date
January 19, 2021
Category
CA Contracts and Indebtedness
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Filing # 121366523 E-Filed 02/15/2021 08:50:43 AM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR LEE COUNTY, FLORIDA CASE NO.: 21-CA-000403 JACK CURREN AND NANCY CURREN, Plaintiffs, VS. UNITED PROPERTY & CASUALTY INSURANCE COMPANY, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’ COMPLAINT COMES NOW, the Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY (hereinafter, the “Defendant”), by and through the undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure, hereby files this Motion for Extension of Time to Respond to the Plaintiffs’ Complaint and as grounds in support thereof, states as follows: 1. Defendant was served with the Complaint on January 26, 2021. 2. The Defendant requires additional time to confer with its counsel, gather the necessary documents, and formulate proper responses to this Complaint. 3. Defendant hereby requests an extension to prepare a response to the Plaintiffs’ Complaint. 4. This request for an extension will not delay this action and neither party will be prejudiced by the granting of this motion. eFiled Lee County Clerk of Courts Page 1CASE NO.: 21-CA-000403 Page 2 of 2 5. The above request for an enlargement of time is asserted in good faith and is not being filed by the undersigned for purposes of delay. WHEREFORE, the Defendant, UNITED PROPERTY & CASUALTY INSURANCE COMPANY, respectfully requests that this Honorable Court enter an Order granting this Motion for Extension of Time, and for all other relief this Honorable Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was filed electronically and was sent by E-mail from the Florida Courts’ E-Filing Portal system, unless otherwise noted below on this 15" day of February , 2021, on all counsel or parties of record listed below: Jared Davis, Esq. KANNER & PINTALIGA, P.A. Attorney for Plaintiffs 925 South Federal Highway Boca Raton, FL 33432 (561) 892-9657 Telephone (561) 583-2188 Facsimile jdavis@kpattorney.com firstpartyeservice@kpattorney.com CHARTWELL LAW Attorneys for Defendant 12486 Brantley Commons Court Fort Myers, FL 33907 (561) 440-5170 Telephone (239) 425-3509 Facsimile By: /4s/Amanda M. Bartley Amanda Bartley, Esq. Florida Bar: 64979 abartley@chartwelllaw.com Christopher R. Cooper, Esq. Florida Bar No. 111434 ccooper@chartwelllaw.com eFiled Lee County Clerk of Courts Page 2