Clerk Notice: GREEN TREE SVCING (LLC) VS MONTENEGRO, JENNY

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                                Electronically Filed 10/31/2013 02:39:18 PM ET




        IN THE CIRCUIT COURT FOR THE ELEVENTH JUDICIAL CIRCUIT
                 IN AND FOR MIAMI-DADE COUNTY, FLORIDA
                             CIVIL ACTION



GREEN TREE SERVICING, LLC,                                     CASE NO.: 2010-30687-CA-01

               PLAINTIFF,

vs.

JENNY MONTENEGRO,            ET AL,

               DEFENDANT(S).


                                      NOTICE OF HEARING
                                                                                            e Master
PLEASE TAKE NOTICE that a hearing has been set before the Presiding Judge of the Foreclosur
                                                                                   the 57 day of
Calendar Court at the Dade County Courthouse, 73 West Flagler Street, Room 3-3, on
November 2013, at 8:30 A.M., or as soon as the matter may be heard, the following:

                              DEFENDANT’S MOTION TO CANCEL AND
                                RESCHEDULE FORECLOSURE SALE

PLEASE GOVERN YOURSELF(VES) ACCORDINGLY.

                                                                                          s
1 HEREBY CERTIFY that a true and correct copy of the foregoing was sent to the Plaintiff'
col  el, SHD Legal Group, P.A., via e-mail to answersidsndiegasro .com on thi ss aay of
                                              answers@shdlegalgroup
             , 2013.

IN ACCORDANCE WITH THE AMERICAN WITH DISABILITIES ACT OF 1990,
                                                              IN THIS
PERSONS NEEDING A SPECIAL ACCOMMODATION TO PARITICPATE
                                                                    AT
PROCEEDING SHOULD CONTACT THE COURT ADMINISTRATOR’S OFFICE
THE LAWSON E. THOMAS COURTHOUSE CENTER, NO LATER        THAN SEVEN
                                                                  G OR
DAYS PRIOR TO THE PROCEEDING AT (305) 349-7152. IF YOU ARE HEARIN
VOICE IMPAIRED, CALL TDD 1-800-955-8771.

                                               BLANCO LAW, P.A.
                                               Attorney for Defendant
                                               11160 N. Kendall Drive, Suite 102
                                               Miami, FL 33176
                                               Phone: (305) 275-2727
                                               Fax:    (305) 275-2728
                                                                      fj
                                              By: CK
                                                                   BLANCO-ELIAS, ESQ.
                                                       orida Bar No.:   0031785


                                                 -1-
IN THE CIRCUIT COURT FOR THE ELEVENTH                           JUDICIAL CIRCUIT
                     IN AND FOR MIAMI-DADE COUNTY,                          FLORIDA

                                             CIVIL ACTION


GREEN TREE SERVICING, LLC,                                             CASE NO.: 2010-30687-CA-01

                   PLAINTIFF,
vs.

JENNY MONTENEGRO, ET AL,
                   DEFENDANT(S).
                                                         /

           EMERGENCY MOTION FOR EXTENSION OF TIME AND CANCELLATION OF
                                          FORECLOSURE        SALE DATE

           COME NOW, JENNY MONTENEGRO,                 by and through her undersigned counsel, and file this

Emergency Motion for Extension of Time and Cancellation of Foreclosure Sale and say as follows:

       1   On or about September 27", 2013, Final Judgment was entered by this court.

      2.   The defendant, MONTENEGRO,         submitted a loan modification to the Plaintiff in this matter.

           As of yet, a loan modification has not been granted and more time is needed in order for said

           application to be processed.

           In light of the fact that MONTENEGRO      has been diligent in her efforts to obtain a loan

           modification but a formal approval has not been provided, MONTENEGRO            respectfully requests

           that the court grant an order postponing the foreclosure sale for at least 90 days in order to allow

           the Plaintiff
                       to continue to process the loan modification.


WHEREFORE,         DEFENDANT, MONTENEGRO,               moves this Court for an Order (1) cancelling the

public sale scheduled for Friday, November 25", 2013; (2) rescheduling the public sale date for at least 90

days; and (3) any other relief that the court may deem just and proper.
CE RTIFICATE OF SERVI         Er

THEREBY CERTIFY that a true and correct copy of the foregoing was sent to the Plaintiff's counsel, SHD

Legal Group, P.A., via e-mail to answers(shdlegalgroup.com on this      day of             2013.




                                                               Georgina Blanco-Elias, Esq.
                                                               BLANCO LAW, P.A.
                                                               11160 N. Kendall Drive, Suite 102
                                                               Miami, FL 33176
                                                               Tel. (305) 275-2727
                                                               Fax (305) 275-2728
                                                               Florida Bar No. 0031785