Continental Casualty Company v. Angelet-Frau et alMOTION for Leave to File Document Reply to Response to Motion to Compel DiscoveryD.P.R.March 11, 2019IN THE UNITED STATED DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO CONTINENTAL CASUALTY COMPANY Plaintiff, v. LUIS M. ANGELET-FRAU, ESQUIRE; VAZQUEZ VIZCARRONDO & ANGELET, LLP; VAZQUEZ VIZCARRONDO, LLP; JUAN VILELLA- JANEIRO, ESQUIRE; VILELLA JANEIRO & JENKS, P.S.C.; ABC INSURANCE COMPANY; XYZ INSURANCE COMPANY; and DEFENDANTS A AND B. Defendants. CIVIL NO. 16-cv-2656 (JAG) DAMAGES, BREACH OF CONTRACT, BREACH OF FIDUCIARY DUTY, CONTRIBUTION AND INDEMNITY JURY TRIAL DEMANDED MOTION REQUESTING LEAVE TO FILE REPLY RESPONSE TO MOTION TO COMPEL DISCOVERY AS TO CODEFENDANT VILELLA AND CROSS-REQUEST FOR URGENT PROTECTIVE ORDER AND/OR TO QUASH DEPOSITION NOTICE (Docket No. 195) COMES NOW Plaintiff CONTINENTAL CASUALTY COMPANY (hereinafter “CCC’) through its undersigned counsel, and very respectfully STATES and PRAYS: On this date, co-defendant Villella-Janeiro and Jenks Law Offices, PSC have filed a Response to Motion to Compel Discovery as to Codefendant Vilella and Cross-request for Urgent Protective Order and/or to Quash Deposition Notice (Docket No. 195). After a careful review of the referenced opposition, CCC believes that a brief reply is warranted in order to counter several factual misrepresentations contained in co-defendants’ Case 3:16-cv-02656-JAG-SCC Document 196 Filed 03/11/19 Page 1 of 2 Motion Requesting Leave… Case No.: 16-cv-2656 (JAG) Page 2 motion. The version of events described therein simply does not conform to what transpired between the parties. Moreover, co-defendant Vilella requests relief as to issues for which he has no standing and/or have been previously discussed with the Court. Therefore, and pursuant to Local Civil Rule 7.1(c), CCC respectfully requests leave from the Court to file a reply motion to Vilella’s opposition. The instant request for leave is sought in good faith, and without the intent of delaying the instant proceedings. WHEREFORE, and pursuant to Local Civil Rule 7.1(c), CCC respectfully requests leave from the Court to file a brief reply to Vilella’s opposition, together with an additional ten (10) day term in which to do so. RESPECTFULLY SUBMITTED. In San Juan, Puerto Rico, this 11th day of March 2019. WE HEREBY CERTIFY: that on this date, we electronically filed the foregoing motion with the Clerk of the Court using the CM/ECF system that will send notification of such filing to all attorneys of record registered in the use of the CM/ECF system. s/Eyck O. Lugo Eyck O. Lugo USDC-PR No.: 216708 E-MAIL:elugo@edgelegalpr.com EDGE Legal Strategies, PSC 252 Ponce de Leon Ave., Suite 2100 San Juan, Puerto Rico 00918 Tel. (787) 522-2000 Fax (787) 522-2010 Case 3:16-cv-02656-JAG-SCC Document 196 Filed 03/11/19 Page 2 of 2
