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PLAINTIFF’S MOTION FOR EXTENSION OF TIME

PLAINTIFF’S MOTION FOR EXTENSION OF TIME


IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

CASE NO.  XX

JENNIFER JAMES,

 

Plaintiff,

vs.

 

TARGET CORPORATION.,

 

Defendant.

__________________________/

 

PLAINTIFF’S MOTION FOR EXTENSION OF TIME

COMES NOW the Plaintiff, JENNIFER JAMES, through the undersigned attorney, and files this Motion for Extension of Time to Respond to Discovery, and as grounds therefor states:

  1. On XX, 20__, the Defendant propounded Interrogatories and a Request for Production upon the Plaintiff.
  2. Although this discovery had been forwarded on to the Plaintiff for a response, the Plaintiff needs additional time to respond.
  3. The Plaintiff requests an additional 30 days (from the date of this motion) in which to respond to Defendant’s discovery.
  4. Rule 1.340 of the Florida Rules of Civil Procedure provides that the Court may allow a longer time within which to respond to the above-described discovery.
  5. This Motion is not being made to delay discovery and, upon completion of the Defendant’s investigation, a response will be promptly filed with the Court.
  6. The granting of this Motion for Extension of Time will not prejudice any party hereto.

 

 

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The pleading above is a sample document related to a specific set of facts and circumstances and should not be used or relied upon for any personal injury matter. This document is being provided for illustrative purposes only. We recommend and urge you to consult with an experienced personal injury lawyer for professional advice as each case is unique.

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