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.
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Filing # MME E-Filed 05/31/2023 01:33:53 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.: 2023CA000041
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 their undersigned counsel,
moves this Court for entry of an order granting Defendant an extension of time of forty-five days
from the date of the order in accordance with Rule 1.090(b), Florida Rules of Civil Procedure, in
which to respond to the Verified Complaint to Foreclose Mortgage (“Complaint”) filed by
Plaintiff, US Bank Trust National Association, etc., (“Plaintiff”), and as grounds therefore states:
1 Defendant needs additional time within which to review and formulate an
appropriate response to the Complaint.
2. Defendant’s undersigned counsel has only been retained recently and has not had
an adequate amount of time to review the Complaint, discuss this matter with Defendant, and
draft an appropriate response to the Complaint.
3 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 of forty-five days from the date of the order to respond to the
Electronically Filed Hamilton Case # 23000041CAAXMX 05/31/2023 01:33:53 PM
Complaint and for such other and further relief as this Court deems appropriate.
Dated: May 30, 2023.
KYLE & KYLE LAW
Attorneys for Defendant, Ruby Williams
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 May 30, 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
May 31, 2023
Case Filing Date
April 28, 2023
Category
Circuit Civil 3-C
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Filing # MME E-Filed 05/31/2023 01:33:53 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.: 2023CA000041 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 their undersigned counsel, moves this Court for entry of an order granting Defendant an extension of time of forty-five days from the date of the order in accordance with Rule 1.090(b), Florida Rules of Civil Procedure, in which to respond to the Verified Complaint to Foreclose Mortgage (“Complaint”) filed by Plaintiff, US Bank Trust National Association, etc., (“Plaintiff”), and as grounds therefore states: 1 Defendant needs additional time within which to review and formulate an appropriate response to the Complaint. 2. Defendant’s undersigned counsel has only been retained recently and has not had an adequate amount of time to review the Complaint, discuss this matter with Defendant, and draft an appropriate response to the Complaint. 3 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 of forty-five days from the date of the order to respond to the Electronically Filed Hamilton Case # 23000041CAAXMX 05/31/2023 01:33:53 PM Complaint and for such other and further relief as this Court deems appropriate. Dated: May 30, 2023. KYLE & KYLE LAW Attorneys for Defendant, Ruby Williams 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 May 30, 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.