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Filing # 145689744 E-Filed 03/14/2022 09:17:04 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT
IN AND FOR FLAGLER COUNTY, FLORIDA
KENNETH BELL, SR., and ALENA BELL,
Case No. 2022-CA-000080
Plaintiffs,
v.
U.S. BANK NATIONAL ASSOCIATION AS
TRUSTEE FOR RAMP 2006ECF2;
EQUIFIRST CORPORATION;
RESIDENTIAL FUNDING COMPANY, LLC
and RESIDENTIAL FUNDING CORP.,
Defendant.
eee
DEFENDANT’S MOTION FOR EXTENSION OF
TIME TO RESPOND TO COMPLAINT
Defendant, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RAMP
2006ECF2, (““USBANK”), pursuant to Fla. R. Civ. P. 1.090(b), hereby moves for an extension of
time to respond to the Verified Complaint to Quiet Title and Cancel Mortgage Lien
(“Complaint”), and in support, states as follows, and in support, states as follows:
1. On or about February 22, 2022, Plaintiffs served the Summons and Complaint on
USBANK.
2. The deadline for USBANK to respond to the Complaint is March 14, 2022.
3. USBANK requires a brief thirty (30) day extension of time to review the
Complaint and further consult with counsel in order to prepare an appropriate response. Also,
due to undersigned counsel’s prior professional commitments, including matters pending in both
State and Federal court, Defendant requires this additional time in which to serve its response to
the Complaint.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 03/15/2022 02:12 PM
4. Further, because the Complaint seeks to invalidate USBANK’s interest in the
Property and Mortgage via the invalidation ofthe interests of USBANK’s predecessors (who may
no longer be in business), it is necessary for this request for extension of time to apply to all
Defendants including EQUIFIRST CORPORATION; RESIDENTIAL FUNDING COMPANY,
LLC and RESIDENTIAL FUNDING CORP.
5. USBANK is not making this request for purposes of delay or harassment and
granting an extension of time will not result in prejudice to either party in this matter.
6. On March 11, 2022, undersigned counsel sought concurrence from Plaintiffs’
counsel (via electronic mail) for the relied requested herein. The parties were unable to reach an
agreement on the relief requested in this Motion.
WHEREFORE, Defendant, USBANK respectfully requests that the Court enter an
Order granting an extension of time to respond to the Complaint up through and including April
11, 2022 and precluding Clerk’s Default from being entered against any Defendant until April
11, 2022.
GREENBERG TRAURIG, P.A.
777 South Flagler Drive, Suite 300 E
West Palm Beach, FL 33401
Tel.: 561.650.7900
By: s/Beth Norrow
Patrick G. Broderick, Esq., FBN 88568
broderickp@gtlaw.com
sandra famadas@egtiaw.com
FLService@etlaw.com
Beth Norrow, Esq., FBN 061497
norrowb@etlaw.com
sandra. famadas(@gtlaw.com
FLService@gtlaw.com
2
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on March 14, 2022, this a true and correct copy of the
foregoing was filed electronically through the Court’s CM/ECF system which will, in turn, send
a notice of electronic filing to parties and counsel of record.
Patricia K. Herman, Esq.
LAW OFFICE OF PATRICIA K. HERMAN, P.A.
1631 Rock Springs Road, #305
Apopka, FL 32712-2229
Tel.: 407.731.5823
lopkhpa@gmail.com
Counselfor Plaintiff
/s/ Beth A. Norrow
BETH A. NORROW
ADMIN 63230334v1
3
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Filing # 145689744 E-Filed 03/14/2022 09:17:04 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, FLORIDA KENNETH BELL, SR., and ALENA BELL, Case No. 2022-CA-000080 Plaintiffs, v. U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RAMP 2006ECF2; EQUIFIRST CORPORATION; RESIDENTIAL FUNDING COMPANY, LLC and RESIDENTIAL FUNDING CORP., Defendant. eee DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT Defendant, U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE FOR RAMP 2006ECF2, (““USBANK”), pursuant to Fla. R. Civ. P. 1.090(b), hereby moves for an extension of time to respond to the Verified Complaint to Quiet Title and Cancel Mortgage Lien (“Complaint”), and in support, states as follows, and in support, states as follows: 1. On or about February 22, 2022, Plaintiffs served the Summons and Complaint on USBANK. 2. The deadline for USBANK to respond to the Complaint is March 14, 2022. 3. USBANK requires a brief thirty (30) day extension of time to review the Complaint and further consult with counsel in order to prepare an appropriate response. Also, due to undersigned counsel’s prior professional commitments, including matters pending in both State and Federal court, Defendant requires this additional time in which to serve its response to the Complaint. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 03/15/2022 02:12 PM 4. Further, because the Complaint seeks to invalidate USBANK’s interest in the Property and Mortgage via the invalidation ofthe interests of USBANK’s predecessors (who may no longer be in business), it is necessary for this request for extension of time to apply to all Defendants including EQUIFIRST CORPORATION; RESIDENTIAL FUNDING COMPANY, LLC and RESIDENTIAL FUNDING CORP. 5. USBANK is not making this request for purposes of delay or harassment and granting an extension of time will not result in prejudice to either party in this matter. 6. On March 11, 2022, undersigned counsel sought concurrence from Plaintiffs’ counsel (via electronic mail) for the relied requested herein. The parties were unable to reach an agreement on the relief requested in this Motion. WHEREFORE, Defendant, USBANK respectfully requests that the Court enter an Order granting an extension of time to respond to the Complaint up through and including April 11, 2022 and precluding Clerk’s Default from being entered against any Defendant until April 11, 2022. GREENBERG TRAURIG, P.A. 777 South Flagler Drive, Suite 300 E West Palm Beach, FL 33401 Tel.: 561.650.7900 By: s/Beth Norrow Patrick G. Broderick, Esq., FBN 88568 broderickp@gtlaw.com sandra famadas@egtiaw.com FLService@etlaw.com Beth Norrow, Esq., FBN 061497 norrowb@etlaw.com sandra. famadas(@gtlaw.com FLService@gtlaw.com 2 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 14, 2022, this a true and correct copy of the foregoing was filed electronically through the Court’s CM/ECF system which will, in turn, send a notice of electronic filing to parties and counsel of record. Patricia K. Herman, Esq. LAW OFFICE OF PATRICIA K. HERMAN, P.A. 1631 Rock Springs Road, #305 Apopka, FL 32712-2229 Tel.: 407.731.5823 lopkhpa@gmail.com Counselfor Plaintiff /s/ Beth A. Norrow BETH A. NORROW ADMIN 63230334v1 3