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Filing# 141142387 E-Filed 12/30/2021 01:21:09 PM
IN THE CIRCUIT COURT OF THE
17 th JUDICIAL CIRCUIT, IN AND FOR
BROWARD, COUNTY, FLORIDA
CASE NO. CACE-21010721
DIVISION 18
JUDGE Fabienne Fahnestock
Telenor Global Services AS
/ Petitioner(s)
Plaintiff(s)
V.
Comtel Direct, LLC
Defendant(s) / Respondent(s) I
DEFENDANT COMTEL DIRECT, LLC MOTION FOR EXTENSION OF TIME
TO SEEK LEGAL COUNSEL
HARRISON VARGAS, on behalf of COMTEL DIRECT, LLC ("Defendant"),pursuant
to Rule 1.090(b),hereby files this Motion for Extension of Time to Seek Legal Counsel. In
support, Defendant states as follows:
1. On December 08 tht 2021, Defendant, through its counsel Robert Stone Jeffrey and
Jeffrey Law, PA requested the Court an entry of an Order permitting counsel
("Jeffrey"), to
withdraw from further representation.
2. On December 15, 2021, honorable Judge Fabienne Fahnestock GRANTED Jeffreythe
Motion to Withdraw as Counsel, permittingDefendant to file an appearance ofnew Counsel within
twenty (20) days from the date the Court entered the Order.
3. Defendants are activelyseekingCounsels to represent multipleintermingleactions:
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/30/2021 01:21:09 PM.****
a) Case No. FMCE19002186, 17th Judicial circuit - Broward County. (Dissolution ofMarriage)
i. Counsel withdraw date: December 7, 2021
ii. Actively looking for Counsel
- (Hearings: Dec 8, 2021, 24, January 2022)
b) Case No. CACE-20-021806, 17th Judicial circuit in Broward County. (Until last week)
i. Counsel withdraw date: December 10, 2021
ii. Deadline: December 30, 2021.
c) Case No. 20-23363-Civ-Cooke/Goodman Southern District of Florida
-
i. Counsel withdraw date: December 17, 2021
ii. Deadline January 5,2022
d) Case No. 0:21-cv-61463-Martinez-Becerra THIS CASE - Southern District of Florida
i. Counsel withdraw date: December 16, 2021
ii. Deadline January 6,2022
e) Case No. CACE-21-010721, THIS CASE 17th Judicial Circuit in Broward County
i. Counsel withdraw date: December 15, 202
ii. Deadline January 4,2022
4. Due to the holiday season, several attorneys are on vacation, making it extremely
challengingfor Defendants to find an appropriaterepresentation
to fulfill its January 4,2022,
deadline.
5. Defendants respectfully
request the Court grant an extra forty-five(45) days Enlargement
of Time to find adequatelyqualified
legalcounsel to assist in preservingour legalrightsin this
complex action.
WHEREFORE, Defendant moves the Court to grant this Motion for Extension of Time
to Seek Legal Counsel.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that 30th day of December 2021, a true and correct copy of the
this
foregoinghas been furnished via E-Mail to: Ravi Batta., Ravi(*rslawpa.com Plainti#Counsel.,
Rosenfeld Stein., allan@rslawpa.com., PlaintiffCounsel., Batta, PA, nelly@rslawpa.com.,
Counsel.
erin@rslawpa.com.,Plaintiff
Respectfully
On Behalf of the Defendant,
Comtel Direct, LLC
Harrison Vargas,
1850 N Corporate Lakes
Blvd, #101, Weston, Florida,
33326 (954) 8642008
- Tel:
Harrison.vargas@icloud.com
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Filing# 141142387 E-Filed 12/30/2021 01:21:09 PM IN THE CIRCUIT COURT OF THE 17 th JUDICIAL CIRCUIT, IN AND FOR BROWARD, COUNTY, FLORIDA CASE NO. CACE-21010721 DIVISION 18 JUDGE Fabienne Fahnestock Telenor Global Services AS / Petitioner(s) Plaintiff(s) V. Comtel Direct, LLC Defendant(s) / Respondent(s) I DEFENDANT COMTEL DIRECT, LLC MOTION FOR EXTENSION OF TIME TO SEEK LEGAL COUNSEL HARRISON VARGAS, on behalf of COMTEL DIRECT, LLC ("Defendant"),pursuant to Rule 1.090(b),hereby files this Motion for Extension of Time to Seek Legal Counsel. In support, Defendant states as follows: 1. On December 08 tht 2021, Defendant, through its counsel Robert Stone Jeffrey and Jeffrey Law, PA requested the Court an entry of an Order permitting counsel ("Jeffrey"), to withdraw from further representation. 2. On December 15, 2021, honorable Judge Fabienne Fahnestock GRANTED Jeffreythe Motion to Withdraw as Counsel, permittingDefendant to file an appearance ofnew Counsel within twenty (20) days from the date the Court entered the Order. 3. Defendants are activelyseekingCounsels to represent multipleintermingleactions: *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/30/2021 01:21:09 PM.**** a) Case No. FMCE19002186, 17th Judicial circuit - Broward County. (Dissolution ofMarriage) i. Counsel withdraw date: December 7, 2021 ii. Actively looking for Counsel - (Hearings: Dec 8, 2021, 24, January 2022) b) Case No. CACE-20-021806, 17th Judicial circuit in Broward County. (Until last week) i. Counsel withdraw date: December 10, 2021 ii. Deadline: December 30, 2021. c) Case No. 20-23363-Civ-Cooke/Goodman Southern District of Florida - i. Counsel withdraw date: December 17, 2021 ii. Deadline January 5,2022 d) Case No. 0:21-cv-61463-Martinez-Becerra THIS CASE - Southern District of Florida i. Counsel withdraw date: December 16, 2021 ii. Deadline January 6,2022 e) Case No. CACE-21-010721, THIS CASE 17th Judicial Circuit in Broward County i. Counsel withdraw date: December 15, 202 ii. Deadline January 4,2022 4. Due to the holiday season, several attorneys are on vacation, making it extremely challengingfor Defendants to find an appropriaterepresentation to fulfill its January 4,2022, deadline. 5. Defendants respectfully request the Court grant an extra forty-five(45) days Enlargement of Time to find adequatelyqualified legalcounsel to assist in preservingour legalrightsin this complex action. WHEREFORE, Defendant moves the Court to grant this Motion for Extension of Time to Seek Legal Counsel. CERTIFICATE OF SERVICE I HEREBY CERTIFY that 30th day of December 2021, a true and correct copy of the this foregoinghas been furnished via E-Mail to: Ravi Batta., Ravi(*rslawpa.com Plainti#Counsel., Rosenfeld Stein., allan@rslawpa.com., PlaintiffCounsel., Batta, PA, nelly@rslawpa.com., Counsel. erin@rslawpa.com.,Plaintiff Respectfully On Behalf of the Defendant, Comtel Direct, LLC Harrison Vargas, 1850 N Corporate Lakes Blvd, #101, Weston, Florida, 33326 (954) 8642008 - Tel: Harrison.vargas@icloud.com