On October 15, 2019 a
Motion for Extension of Time - TO RESPOND TO DISCOVERYParty: Plaintiff Ordonez, Doreen B Plaintiff Ordonez, Mitchelle R
was filed
involving a dispute between
Ordonez, Doreen B,
Ordonez, Mitchelle R,
and
Universal Property And Casualty Insurance Company,
for 3
in the District Court of Broward County.
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Filing # 102687832 E-Filed 02/04/2020 08:55:17 AM
MITCHELLE R ORDONEZ, an individual,
and DOREEN B ORDONEZ, an individual,
Plaintiffs,
v.
UNIVERSAL PROPERTY & CASUALTY
INSURANCE COMPANY, a Florida
governmental entity,
Defendant.
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: CACE-19-021656
MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY
COME NOW, the Plaintiffs, MITCHELLE R ORDONEZ, and DOREEN B ORDONEZ
(collectively the “Plaintiff”), by and through the undersigned counsel, hereby respectfully requests
an Extension of Time in which to file and serve responses to Defendant’s, UNIVERSAL
PROPERTY & CASUALTY INSURANCE COMPANY (the “Defendant”), First Request for
Production to Plaintiffs and First Set of Interrogatories to Plaintiffs, pursuant to FLA. R. CIv. P.
1.090 and Florida law, and in support thereof states as follows:
1. The Plaintiffs are gathering the information necessary to comply with the
Defendant’s discovery request. Accordingly, the Plaintiffs now seeks an enlargement of time in
which to do so.
2. FLA. R. Civ. P. 1.090(b) states in pertinent part as follows:
“When an act is required or allowed to be done at or within a specified time by order of the
court, by these rules, or by notice given there under, for cause shown the court at any time,
in its discretion (1) with or without 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, or (2) upon motion made and notice after the expiration of the specified
period, may permit the act to be done when failure to act was the result of excusable
neglect...”
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2020 08:55:17 AM.****3. Jub. R. ADMIN. 2.514(b) states in pertinent part as follows: “[w]hen a party may or
must act within a specified time after service and service is made by mail or e-mail, 5 days are
added after the period that would otherwise expire under subdivision (a).”
4. There is no prejudice to Defendant as this matter is in the beginning stages of
litigation.
5. This motion is not filed for an improper purpose or to delay the cause.
WHEREFORE the Plaintiffs, MITCHELLE R ORDONEZ, and DOREEN B ORDONEZ,
respectfully requests that this Honorable Court enter an Order Granting additional days in which
to respond to the Defendant’s discovery request.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via E-
Filings to: Ashley Joseph , Esq., of UNIVERSAL PROPERTY & CASUALTY INS. CO., at
upciceservice02@universalproperty.com; mm0107@universalproperty.com; on this 4° day of
February, 2020.
SILVERBERG|BRITO, PLLC
1200 NW 78th Avenue, Suite 302
Miami, Florida 33126
Telephone No. (305) 735-3966
Facsimile No. (305) 440-1055
Primary Email: eservice@silverbergbrito.com
Secondary Email: dalyz@silverbergbrito.com
By: 4s/Dalyz Limia
Gisel Brito, Esq.
Florida Bar No. 90925
Dalyz Limia, Esq.
Florida Bar No. 1017895
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Filing # 102687832 E-Filed 02/04/2020 08:55:17 AM MITCHELLE R ORDONEZ, an individual, and DOREEN B ORDONEZ, an individual, Plaintiffs, v. UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, a Florida governmental entity, Defendant. IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: CACE-19-021656 MOTION FOR EXTENSION OF TIME TO RESPOND TO DISCOVERY COME NOW, the Plaintiffs, MITCHELLE R ORDONEZ, and DOREEN B ORDONEZ (collectively the “Plaintiff”), by and through the undersigned counsel, hereby respectfully requests an Extension of Time in which to file and serve responses to Defendant’s, UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY (the “Defendant”), First Request for Production to Plaintiffs and First Set of Interrogatories to Plaintiffs, pursuant to FLA. R. CIv. P. 1.090 and Florida law, and in support thereof states as follows: 1. The Plaintiffs are gathering the information necessary to comply with the Defendant’s discovery request. Accordingly, the Plaintiffs now seeks an enlargement of time in which to do so. 2. FLA. R. Civ. P. 1.090(b) states in pertinent part as follows: “When an act is required or allowed to be done at or within a specified time by order of the court, by these rules, or by notice given there under, for cause shown the court at any time, in its discretion (1) with or without 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, or (2) upon motion made and notice after the expiration of the specified period, may permit the act to be done when failure to act was the result of excusable neglect...” *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/04/2020 08:55:17 AM.****3. Jub. R. ADMIN. 2.514(b) states in pertinent part as follows: “[w]hen a party may or must act within a specified time after service and service is made by mail or e-mail, 5 days are added after the period that would otherwise expire under subdivision (a).” 4. There is no prejudice to Defendant as this matter is in the beginning stages of litigation. 5. This motion is not filed for an improper purpose or to delay the cause. WHEREFORE the Plaintiffs, MITCHELLE R ORDONEZ, and DOREEN B ORDONEZ, respectfully requests that this Honorable Court enter an Order Granting additional days in which to respond to the Defendant’s discovery request. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via E- Filings to: Ashley Joseph , Esq., of UNIVERSAL PROPERTY & CASUALTY INS. CO., at upciceservice02@universalproperty.com; mm0107@universalproperty.com; on this 4° day of February, 2020. SILVERBERG|BRITO, PLLC 1200 NW 78th Avenue, Suite 302 Miami, Florida 33126 Telephone No. (305) 735-3966 Facsimile No. (305) 440-1055 Primary Email: eservice@silverbergbrito.com Secondary Email: dalyz@silverbergbrito.com By: 4s/Dalyz Limia Gisel Brito, Esq. Florida Bar No. 90925 Dalyz Limia, Esq. Florida Bar No. 1017895