Motion,Ex Parte: SOLANO, RAMON Aet al. vs. UNIVERSAL INSURANCE COMPANY OF NORTH AMERICA

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                                Filing #61440996 E-Filed 09/07/2017 02:45:14 PM


                                                           IN THE CIRCUIT COURT OF THE NINTH
                                                           JUDICIAL   CIRCUIT  IN  AND   FOR
                                                           ORANGE COUNTY, FLORIDA

                                                           CASE NO. 2017-CA-004877-O
         RAMON A. SOLANO
         and JOSEFINA SOLANO,

               Plaintiffs,

         vs.


        UNIVERSAL INSURANCE COMPANY
        OF NORTH AMERICA,

               Defendant.
                                                 /

                             DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
                              RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS

                    Defendant,    UNIVERSAL       INSURANCE      COMPANY      OF   NORTH    AMERICA,

        pursuant to Rules 1.280, 1.340 and 1.350, Florida Rules of Civil Procedure, requests this

        Court to enter an Order granting Defendant an extension of time to respond to Plaintiffs

        First Set of Interrogatories and First Request to Produce served on Defendant by the

        Plaintiff on July 6, 2017, on the following grounds:


                    1         Plaintiff served Defendant with a First Request to Produce, First Set of

        Interrogatories and Request for Admissions on July 26, 2017.

                    2         Due to the anticipated arrival of Hurricane Irma, the Defendant will need

        additional time to compile the information needed to respond to Plaintiff's discovery

        requests.

                    3         Defendant requests an extension of fourteen (14) days in which to respond

        to Plaintiff's discovery requests.
4   On September 7, 2017, counsel for the Plaintiff agreed to extending an

additional fourteen (14) days in which to respond to the Plaintiffs discovery requests.

           5   Defendant    asserts that it is not filing this Motion    as a means   to delay

discovery, and therefore, Defendant should be granted an extension of time to respond to

any outstanding discovery requests.

       WHEREFORE           Defendant,     UNIVERSAL    NORTH        AMERICA,      respectfully

requests that this Honorable Court grant its’ Motion for Extension of Time to Respond to

Plaintiff's Discovery Requests and allow Defendant an additional fourteen (14) days in

which to respond to Plaintiff's discovery requests.

                              CERTIFICATE OF SERVICE

       I HEREBY        CERTIFY    that a true and correct copy of the foregoing has been
furnished via electronic mail on the 7” day of September, 2017 to David D. Gongora,
Esquire, Law Office of David D. Gongora, P.A., 5401            South Kirkman Rd., Suite 310,
Orlando,          FL             32819;         DavidGongoraEsq@gmail.com                  and
LegalAssistA@davidgongora.com.




                                                          <2              eon
                                              Andrew P.Rock, Esquire
                                              Florida Bar No. 0656437
                                              F. Caroline H. Cranton, Esq.
                                              Florida Bar No. 96369
                                              The Rock Law Group, P.A.
                                              1760 Fennell Street
                                              Maitland, FL 32751
                                              Telephone: (407) 647-9881
                                              Telecopier: (407) 647-9966
                                              Attorneys for Defendant, Universal Insurance
                                              Company of North America