On November 13, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Ibm Southeast Employees Credit,
and
Sinclair, Errol,
for Circuit Civil 3-D
in the District Court of Marion County.
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Filing # 101052907 E-Filed 01/02/2020 05:26:11 PM
IN THE CIRCUIT COURT OF THE 5TH JUDICIAL CIRCUIT
IN AND FOR MARION COUNTY, FLORIDA
IBM Southeast Employees’ Credit Union, CASE NO.: 2019-CA-002488
Plaintiff,
vs.
Errol Sinclair,
Defendant.
MOTION TO TRANSFER ACTION TO COUNTY COURT
COMES NOW the Plaintiff, IBM Southeast Employees’ Credit Union, and hereby files
this Motion to Transfer Action to County Court and as grounds therefore would state as follows:
1. This is a collection action wherein the principal amount allegedly owed by
Defendant to Plaintiff is $14,236.33. Through inadvertence, this action was filed in the Circuit
Court as opposed to the County Court. In order to remedy this, Plaintiff is filing this Motion to
Transfer so that the Circuit Court enters an Order transferring this action to the County Court which
is the Court with proper jurisdiction in order to determine this action on the merits.
2. There would be no prejudice to Defendant by the Court granting this Motion. The
Defendant will have the full opportunity to allege any defenses Defendant may have to this action
and to assert Defendant’s position before the Court.
Electronically Filed Marion Case # 19CA002488AX 01/02/2020 05:26:11 PMWHEREFORE, Plaintiff, IBM Southeast Employees’ Credit Union, respectfully requests
this Honorable Court enter an Order granting Plaintiff's Motion to Transfer Action to County
Court for the reasons above alleged.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
n>
U.S. mail to Errol Sinclair at 2603 SW 10" Street, Apt 371, Ocala, FL 34471 on this 2 day of
Tae: , 2020.
BY:
é Cohen, Esquire
Florida Bar No.: 251062
c/o &ccounts Receivables Inc
2475 Mercer Ave, B307
West Palm Beach FL 33401
Phone: (561) 453-0880
Fax: (561) 214-4168
Mare@4aronline.com
Document Filed Date
January 02, 2020
Case Filing Date
November 13, 2019
Category
Circuit Civil 3-D
Status
CLOSED - TRANSFERRED
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Filing # 101052907 E-Filed 01/02/2020 05:26:11 PM IN THE CIRCUIT COURT OF THE 5TH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA IBM Southeast Employees’ Credit Union, CASE NO.: 2019-CA-002488 Plaintiff, vs. Errol Sinclair, Defendant. MOTION TO TRANSFER ACTION TO COUNTY COURT COMES NOW the Plaintiff, IBM Southeast Employees’ Credit Union, and hereby files this Motion to Transfer Action to County Court and as grounds therefore would state as follows: 1. This is a collection action wherein the principal amount allegedly owed by Defendant to Plaintiff is $14,236.33. Through inadvertence, this action was filed in the Circuit Court as opposed to the County Court. In order to remedy this, Plaintiff is filing this Motion to Transfer so that the Circuit Court enters an Order transferring this action to the County Court which is the Court with proper jurisdiction in order to determine this action on the merits. 2. There would be no prejudice to Defendant by the Court granting this Motion. The Defendant will have the full opportunity to allege any defenses Defendant may have to this action and to assert Defendant’s position before the Court. Electronically Filed Marion Case # 19CA002488AX 01/02/2020 05:26:11 PMWHEREFORE, Plaintiff, IBM Southeast Employees’ Credit Union, respectfully requests this Honorable Court enter an Order granting Plaintiff's Motion to Transfer Action to County Court for the reasons above alleged. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via n> U.S. mail to Errol Sinclair at 2603 SW 10" Street, Apt 371, Ocala, FL 34471 on this 2 day of Tae: , 2020. BY: é Cohen, Esquire Florida Bar No.: 251062 c/o &ccounts Receivables Inc 2475 Mercer Ave, B307 West Palm Beach FL 33401 Phone: (561) 453-0880 Fax: (561) 214-4168 Mare@4aronline.com