Document for Kamla Chaudhari, et al Plaintiff vs. Safepoint Insurance Company Defendant

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                                Filing # 100650082 E-Filed 12/20/2019 12:34:58 PM

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

KAMLA CHAUDHARI and
HEMENDRA CHAUDHARI,

Plaintiffs,
v. Case No.: CACE-19-021689

SAFEPOINT INSURANCE COMPANY,

Defendant.
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DEFENDANT, SAFEPOINT INSURANCE COMPANY’S
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFFS’
INITIAL DISCOVERY REQUESTS

COMES NOW, Defendant, SAFEPOINT INSURANCE COMPANY (“SafePoint”), by
and through its undersigned counsel, hereby moves for an extension of time to respond to
Plaintiffs’ First Set of Interrogatories and First Request for Production (“Initial Discovery
Requests”), and as grounds therefore states as follows:

1. This matter arises out of a homeowner’s insurance claim dispute brought
by Plaintiffs against Defendant.

2. The undersigned is in receipt of Plaintiffs’ initial discovery requests, specifically
Plaintiffs’ First Set of Interrogatories and First Request for Production, served with the
Complaint.

3. The undersigned respectfully requests an additional thirty (30) days to respond to

Plaintiffs’ initial discovery requests.

4. There is no trial pending in this matter. Furthermore, this motion is not intended
for purposes of delay.
5. The granting of this motion will not prejudice either party.

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/20/2019 12:34:58 PM.****WHEREFORE, Defendant respectfully requests that this Court enter an Order granting
Defendant’s Motion for Extension of Time to Respond to Plaintiffs’ Initial Discovery Requests.
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 20" day of December 2019, a true and correct copy of
the foregoing was filed with the Clerk of Court by using the Florida court’s e-filing portal, which
will send an automatic email message to the following parties registered with the e-filing portal
system: Neil M. Khan, The Khan Law Firm, 1521 Alton Road, Suite 784, Miami Beach, Florida
33139 | neilk@khanlaw.attomey (Counsel for Plaintiffs)

By:  4s/Stefanie L. Rosen
Stefanie L. Rosen
Florida Bar No.: 99355
SafePoint Insurance Company
P.O. Box 291579
Tampa, Florida 33687
Email: srosen@safepointins.com;
ahin@safepointins.com
Phone: (813) 296-8506 / Fax: (813) 534-5108
Counsel for Defendant, SafePoint Insurance Company