On December 20, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Bank Of America Na,
and
Ranallo, John E,
for Contract and Indebtedness
in the District Court of Collier County.
Preview
Filing # 72399042 E-Filed 05/21/2018 07:36:17 AM
IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
BANK OF AMERICA, N.A., )
Plaintiff, ) CIVIL ACTION
)
vs. )
) CASE NO. 112017CA0021870
JOHN E RANALLO, )
Defendant. )
/
MOTION FOR ENLARGEMENT OF TIME TO SERVE DEFENDANT
COMES NOW the Plaintiff, by and through the undersigned Counsel, and pursuant to Florida Rules of
Civil Procedure 1.090(b) and 1.070(j), hereby files this Motion for Enlargement of Time to Serve Defendant,
and as cause wherefore states the following:
1, The complaint for this instant action was filed on or about December 20, 2017;
2. Asummons was issued for Defendant, but the verified return on non-service states the Process Server
was unable to make contact with the Defendant;
3. To date, Plaintiff has been unable to locate the Defendant for Service. Upon information and belief,
Plaintiff now believes it has a valid address for service; and
4. The 120-day time limit for service expired on or about December April 20, 2108.
WHEREFORE, for the foregoing, Plaintiff respectfully requests an Order granting additional time to
effect service upon the Defendant so a summons can be placed out for service.
A >
__Anson A. Adams, FL Bar #: 0115094
Rafael Caraballo, FL Bar # 124632
rea L. Davis, FL Bar #: 1005230
ROCK & SCOTT, PLLC
1315 Westbrook Plaza Drive
Winston-Salem, NC 27103
Phone: (888) 461-7908
Fax: (336) 354-1588
flcolservice@brockandscott.com
FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 05/21/2018 09:07:44 AMCERTIFICATE OF SERVICE
a
3
1 HEREBY CERTIFY that a true and correct copy of the foregoing was furnished on this Z‘ day of
20_ to:
JOHN E RANALLO
By U.S. Mail:
794 111TH AVEN
NAPLES FL 34108-1828
__Anson A. Adams, FL Bar #: 0115094
__ Rafael Caraballo, FL Bar #; 124632
Andrea L. Davis, FL Bar #: 1005230
This communication is from a debt collector.
This is an attempt to collect a debt and any information obtained will be used for that purpose.
¢\AR002023
Case Filing Date
December 20, 2017
Category
Contract and Indebtedness
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Preview
Filing # 72399042 E-Filed 05/21/2018 07:36:17 AM IN THE CIRCUIT COURT OF THE 20TH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA BANK OF AMERICA, N.A., ) Plaintiff, ) CIVIL ACTION ) vs. ) ) CASE NO. 112017CA0021870 JOHN E RANALLO, ) Defendant. ) / MOTION FOR ENLARGEMENT OF TIME TO SERVE DEFENDANT COMES NOW the Plaintiff, by and through the undersigned Counsel, and pursuant to Florida Rules of Civil Procedure 1.090(b) and 1.070(j), hereby files this Motion for Enlargement of Time to Serve Defendant, and as cause wherefore states the following: 1, The complaint for this instant action was filed on or about December 20, 2017; 2. Asummons was issued for Defendant, but the verified return on non-service states the Process Server was unable to make contact with the Defendant; 3. To date, Plaintiff has been unable to locate the Defendant for Service. Upon information and belief, Plaintiff now believes it has a valid address for service; and 4. The 120-day time limit for service expired on or about December April 20, 2108. WHEREFORE, for the foregoing, Plaintiff respectfully requests an Order granting additional time to effect service upon the Defendant so a summons can be placed out for service. A > __Anson A. Adams, FL Bar #: 0115094 Rafael Caraballo, FL Bar # 124632 rea L. Davis, FL Bar #: 1005230 ROCK & SCOTT, PLLC 1315 Westbrook Plaza Drive Winston-Salem, NC 27103 Phone: (888) 461-7908 Fax: (336) 354-1588 flcolservice@brockandscott.com FILED: COLLIER COUNTY, DWIGHT E. BROCK, CLERK, 05/21/2018 09:07:44 AMCERTIFICATE OF SERVICE a 3 1 HEREBY CERTIFY that a true and correct copy of the foregoing was furnished on this Z‘ day of 20_ to: JOHN E RANALLO By U.S. Mail: 794 111TH AVEN NAPLES FL 34108-1828 __Anson A. Adams, FL Bar #: 0115094 __ Rafael Caraballo, FL Bar #; 124632 Andrea L. Davis, FL Bar #: 1005230 This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. ¢\AR002023