In any of your jurisdictions, do you have a statute that extends your time to do any act or make any response when service is made by mail/overnight/fax/e-service? In California, this is CCP 1013.

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In Florida, 5 additional days are added to a deadline to respond if delivery of a document requiring a response, such as a discovery request, is by mail.

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I think you’ll find a similar statute in just about every state. The number of days will vary, but the addition of days when required to respond to something served by U.S. Mail, overnight delivery, etc. is pretty common.

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