On August 11, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Ocean Bank,
and
Dream Show Productions 2020, Llc,
Entertainment Advisors Of Florida Llc,
Urbina, Stephanie,
Valarino, Mercedes,
for Business Torts
in the District Court of Miami-Dade County.
Preview
Filing # 134465915 E-Filed 09/13/2021 02:02:18 PM
IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR
MIAMI DADE COUNTY, FLORIDA
OCEAN BANK, CIVIL DIVISON
Plaintiff,
vs. MAIN
CASE NO.: 20-10948 CA 01
BLUE CONCERTS, LLC AND VICTOR ALAIN
BELTRAN DE LA PARTE,
Defendants.
___________________________________________/
OCEAN BANK,
Plaintiff,
vs.
DREAM SHOW PRODUCTIONS 2020 LLC, SUPPLEMENTAL
ENTERTAINMENT ADVISORS OF FLORIDA CASE NO.: 21-019003 CA 01
LLC, MERCEDES VALARINO, and STEPHANIE
URBINA
Impleaded Defendants.
___________________________________________/
MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
Defendants, ENTERTAINMENT ADVISORS OF FLORIDA, LLC, MERCEDES
VALARINO, and STEPHANIE URBINA, by and through undersigned counsel, files this Motion
for Extension of Time to Respond to Complaint and in support thereof, states as follows:
1. Undersigned counsel has recently been retained by Defendants and has not had an
opportunity to meet with his clients regarding this matter to gather the necessary information to
frame a response to Plaintiff’s Complaint.
2. Defendants therefore respectfully request an extension of time within which to file a
response to Plaintiff’s Complaint.
3. Defendants’ request for an extension of time will not prejudice the Plaintiff in this
action.
4. Undersigned counsel certifies that this Motion is made in good faith and not for the
purpose of delay, but so that justice may be done.
WHEREFORE, Defendants respectfully request that this Court enter an Order granting
an extension of time within which to file a response to Plaintiff’s Complaint and for such further
relief as the Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of September 2021, a true and correct copy
of the foregoing has been furnished via electronic mail to: Weissman & Dervishi, P.A., c/o Peter
A. Tappert, Esquire at ptappert@wdpalaw.com.
Law Offices of Samir Masri
901 Ponce de Leon Blvd., Suite 101
Coral Gables, FL 33134
Tel: (305) 445-3422
E-service: masrilaw@aol.com
By: s/ Samir Masri
Samir Masri, Esquire
FBN: 145513
Document Filed Date
September 13, 2021
Case Filing Date
August 11, 2021
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 134465915 E-Filed 09/13/2021 02:02:18 PM IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT IN AND FOR MIAMI DADE COUNTY, FLORIDA OCEAN BANK, CIVIL DIVISON Plaintiff, vs. MAIN CASE NO.: 20-10948 CA 01 BLUE CONCERTS, LLC AND VICTOR ALAIN BELTRAN DE LA PARTE, Defendants. ___________________________________________/ OCEAN BANK, Plaintiff, vs. DREAM SHOW PRODUCTIONS 2020 LLC, SUPPLEMENTAL ENTERTAINMENT ADVISORS OF FLORIDA CASE NO.: 21-019003 CA 01 LLC, MERCEDES VALARINO, and STEPHANIE URBINA Impleaded Defendants. ___________________________________________/ MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT Defendants, ENTERTAINMENT ADVISORS OF FLORIDA, LLC, MERCEDES VALARINO, and STEPHANIE URBINA, by and through undersigned counsel, files this Motion for Extension of Time to Respond to Complaint and in support thereof, states as follows: 1. Undersigned counsel has recently been retained by Defendants and has not had an opportunity to meet with his clients regarding this matter to gather the necessary information to frame a response to Plaintiff’s Complaint. 2. Defendants therefore respectfully request an extension of time within which to file a response to Plaintiff’s Complaint. 3. Defendants’ request for an extension of time will not prejudice the Plaintiff in this action. 4. Undersigned counsel certifies that this Motion is made in good faith and not for the purpose of delay, but so that justice may be done. WHEREFORE, Defendants respectfully request that this Court enter an Order granting an extension of time within which to file a response to Plaintiff’s Complaint and for such further relief as the Court deems just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 13th day of September 2021, a true and correct copy of the foregoing has been furnished via electronic mail to: Weissman & Dervishi, P.A., c/o Peter A. Tappert, Esquire at ptappert@wdpalaw.com. Law Offices of Samir Masri 901 Ponce de Leon Blvd., Suite 101 Coral Gables, FL 33134 Tel: (305) 445-3422 E-service: masrilaw@aol.com By: s/ Samir Masri Samir Masri, Esquire FBN: 145513