On January 26, 2018 a
Motion for Extension of Time - / DISCOVERY REQUESTSParty: Plaintiff Kahan, Maurice
was filed
involving a dispute between
Kahan, Maurice,
and
Safepoint Insurance Company,
for Other - Insurance Claim
in the District Court of Broward County.
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Filing # 83216349 E-Filed 01/11/2019 12:44:38 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
MAURICE KAHAN,
Plaintiff,
vs.
CASE NO: CACE-18-002004
SAFEPOINT INSURANCE COMPANY,
RRR HR HHH
Defendant,
PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
DEFENDANT’S DISCOVERY REQUESTS
The Plaintiff, Maurice Kahan, by and through his undersigned attorneys, files this Motion
for Extension of Time to respond to the Defendant’s Discovery Requests and as grounds
therefore would state as follows:
1. On or about December 12, 2019 Defendant served Plaintiff with First Set of
Interrogatories to Plaintiff, Second Set of Interrogatories to Plaintiff, First Request for
Production and Second Request for Production.
2. Plaintiff is hereby requesting additional time to adequately respond to these
discovery requests.
3. Discovery in this matter is in its infancy.
4. This Motion is not dilatory in nature, and there will be no prejudice to the
Defendant in the granting of this motion.
5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time
within which to respond to the Defendant’s discovery requests.
6. The Plaintiff reserves the right to object to any of the Defendant’s discovery
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/11/2019 12:44:38 PM.****based upon work product, attorney-client or other applicable privilege, protection or immunity
from discovery.
WHEREFORE, Plaintiff, Maurice Kahan, respectfully requests this Court grant this
Motion for Extension of Time to Respond to Defendant’s Discovery Requests and for such other
relief this Court deems just and equitable.
CERTIFICATE OF SERVICE
THIS IS TO CERTIFY that on the {I™” day of Jan“avy 2019, a true and
correct copy of the foregoing was served via the Florida Courts E-filing Portal on all counsel and
pro se parties of record.
THE RAIN LAW FIRM
Counsel for Plaintiff
1930 Harrison Street Suite 506
Hollywood, Florida 33020
Telephone: 855.330.7246
Fax: 954.343.1144
Email: gsalas@therainlawfirm.com
mkotzen@therainlawfirm.com
By: _/s/ Gabriel de las Salas
Gabriel de las Salas, Esq.
Florida Bar No. 85691
Matthew C. Kotzen, Esq.
Florida Bar No. 113085
Document Filed Date
January 11, 2019
Case Filing Date
January 26, 2018
Category
Other - Insurance Claim
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Filing # 83216349 E-Filed 01/11/2019 12:44:38 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MAURICE KAHAN, Plaintiff, vs. CASE NO: CACE-18-002004 SAFEPOINT INSURANCE COMPANY, RRR HR HHH Defendant, PLAINTIFF’S MOTION FOR EXTENSION OF TIME TO RESPOND TO DEFENDANT’S DISCOVERY REQUESTS The Plaintiff, Maurice Kahan, by and through his undersigned attorneys, files this Motion for Extension of Time to respond to the Defendant’s Discovery Requests and as grounds therefore would state as follows: 1. On or about December 12, 2019 Defendant served Plaintiff with First Set of Interrogatories to Plaintiff, Second Set of Interrogatories to Plaintiff, First Request for Production and Second Request for Production. 2. Plaintiff is hereby requesting additional time to adequately respond to these discovery requests. 3. Discovery in this matter is in its infancy. 4. This Motion is not dilatory in nature, and there will be no prejudice to the Defendant in the granting of this motion. 5. Florida Rules of Civil Procedure 1.090(b) allows this Court to extend the time within which to respond to the Defendant’s discovery requests. 6. The Plaintiff reserves the right to object to any of the Defendant’s discovery *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 1/11/2019 12:44:38 PM.****based upon work product, attorney-client or other applicable privilege, protection or immunity from discovery. WHEREFORE, Plaintiff, Maurice Kahan, respectfully requests this Court grant this Motion for Extension of Time to Respond to Defendant’s Discovery Requests and for such other relief this Court deems just and equitable. CERTIFICATE OF SERVICE THIS IS TO CERTIFY that on the {I™” day of Jan“avy 2019, a true and correct copy of the foregoing was served via the Florida Courts E-filing Portal on all counsel and pro se parties of record. THE RAIN LAW FIRM Counsel for Plaintiff 1930 Harrison Street Suite 506 Hollywood, Florida 33020 Telephone: 855.330.7246 Fax: 954.343.1144 Email: gsalas@therainlawfirm.com mkotzen@therainlawfirm.com By: _/s/ Gabriel de las Salas Gabriel de las Salas, Esq. Florida Bar No. 85691 Matthew C. Kotzen, Esq. Florida Bar No. 113085