On April 28, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Us Bank Trust National Associa,
and
Town Of White Springs Florida,
Unknown Spouse Of Bernard L Wi,
Unknown Spouse Of Ruby T Willi,
Unknown Tenant 1,
Unknown Tenant 2,
Williams, Bernard L,
Williams, Ruby T,
for Circuit Civil 3-C
in the District Court of Hamilton County.
Preview
Filing # MM E-Filed 10/25/2023 01:50:37 PM
IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT
IN AND FOR HAMILTON COUNTY, FLORIDA
CIVIL ACTION
US BANK TRUST NATIONAL ASSOCIATION, ete., CASE NO.: 2023CA41
Plaintiff,
Vv.
RUBY T. WILLIAMS; et al.,
Defendants.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO VERIFIED COMPLAINT TO FORECLOSE MORTGAGE
Defendant, Ruby Williams (“Defendant”), by and through Defendant’s undersigned
counsel, move this Court for entry of an order granting Defendant an extension of time in
accordance with Rule 1.090(b), Florida Rules of Civil Procedure, in which to respond to
Plaintiff's First Request for Production to Defendants (collectively “Discovery Requests”) filed
and/or served by Plaintiff, U.S. Bank Trust, N.A., ete. (“Plaintiff”), and as grounds therefore
state:
1 Defendant needs additional time within which to review and formulate an
appropriate response to the Discovery Requests.
2. Defendant’s request for additional time is made in good faith and not for the
purpose of delay. Plaintiff will not be prejudiced by an extension of time.
WHEREFORE, Defendant respectfully requests this Court to enter an order granting
Defendant an extension of time to respond to the Discovery Requests and for such other and
Electronically Filed Hamilton Case # 23000041CAAXMX 10/25/2023 01:50:37 PM
further relief as this Court deems appropriate.
Dated: October 25, 2023.
KYLE & KYLE LAW
Attorneys for Defendan
2241 N. Monroe St., #1096
Tallahassee, FL 32303
(850) 270-7604
john@kyleandkylelaw.com
By: _4s/ John Lara
John Lara, Esq.
Florida Bar Number: 1041177
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by
electronic mail or U.S. Mail on October 25, 2023, to:
Howard Law Group
4755 Technology Way, Suite 104
Boca Raton, FL 33431
pleadings@howardlaw.com
Attorneys for Plaintiff
4s/ John Lara
John Lara, Esq.
Document Filed Date
October 25, 2023
Case Filing Date
April 28, 2023
Category
Circuit Civil 3-C
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