Legal Question in Civil Litigation in Florida

You did not specify what court you're talking about, but I will assume you're talking about Florida State Court (not small claims). A motion to extend time for answering a complaint is not a proper response pursuant to the Florida Rules of Civil Procedure. The whole purpose for filing such a document would be to put something into the court file to prevent a clerk's default from being entered. Now, it may protect you from a clerk's default, but not necessarily a judge's default, as judges will have discretion and can enter default if a response has not been filed in accordance with the Rules. Also, if you are filing motions for purposes of delay, you may eventually be subject to sanctions, which may include default against you.

The proper way to extend time to answer a complaint is to contact opposing counsel and ask if they will stipulate to an extension of time to prepare your response, within which they will not move for default. Most attorneys will be agreeable to such a request -- within reason. Repeated motions to extend time can be an abuse of the court system and will not be looked upon favorably by opposing counsel or the presiding judge.