On June 29, 2022 a
MOTION
was filed
involving a dispute between
Matrix Financial Services Corp,
and
Flagstar Bank, Fsb,
Lewis, Dennis M,
Lewis, Jessica Sarah,
Unknown Tenant No 1,
Unknown Tenant No 2,
for Circuit Civil 3-C
in the District Court of Glades County.
Preview
Filing # 183219626 E-Filed 10/04/2023 01:08:27 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR GLADES COUNTY, FLORIDA CIVIL DIVISION
MATRIX FINANCIAL SERVICES CORP,
Plaintiff,
VS. CASE NO. 2022-CA-000085
DENNIS M. LEWIS A/K/A DENNIS MATTHEW
LEWIS F/K/A DENNIS MATTEW LEWIS et al.,
Defendants,
/
PLAINTIFF’S MOTION TO_CANCEL AND RESET FORECLOSURE SALE
COMES NOW, Plaintiff, MATRIX FINANCIAL SERVICES CORP (“Plaintiff”), by
and through undersigned counsel, does hereby file this Motion to Cancel and Reset Foreclosure
Sale and states:
1 On July 29, 2023, this Court entered Final Judgment of Foreclosure pursuant
to which a foreclosure sale was set for November 2023.
2. The November 2, 2023, sale needs to be cancelled as Plaintiff and Defendant are
engaged in loss mitigation. Defendant has been approved for a trial loan modification and has
already submitted two payment.
3. Plaintiff respectfully requests that this Court reset the sale for a date no sooner than
February 2023.
WHEREFORE, Plaintiff respectfully requests that this Court enter an Order cancelling
and resetting the foreclosure sale and for such further relief this Court deems just and proper.
Dated this 4" day of October 2023.
SOKOLOF REMTULLA, PLLC
By: /s/ Benjamin D. Ladouceur
Benjamin D. Ladouceur, Esq.
Florida Bar No.: 73863
Primary e-mail: bladouceur@sokrem.com
SOK TEND. CC
Electronically Filed Glades Case # 22000085CAMXAX 40/04/2023 01:08:27 PM
Secondary e-mail: pleadings(@sokrem.com
6801 Lake Worth Road, Suite 100E
Greenacres, Florida 33467
Telephone: 561-507-5252
Facsimile: 561-342-4842
Counsel for Plaintiff
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with
the Clerk of Court using the Florida Courts E-Filing Portal, and a copy has been served via E-
mail or U.S. Mail to the parties listed below on this 4" day of October 2023.
Dennis M. Lewis A/K/A Dennis Matthew Lewis F/K/A Dennis Mattew Lewis, 1497 Muse
Road, Labelle, FL 33935, e-mail: Idl-properties@outlook.com
Jessica Lewis, 1497 Muse Road, Labelle, FL 33935, e-mail: {dl.properties@outlook.com
/s/_ Benjamin D. Ladouceur
Document Filed Date
October 04, 2023
Case Filing Date
June 29, 2022
Category
Circuit Civil 3-C
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Filing # 183219626 E-Filed 10/04/2023 01:08:27 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR GLADES COUNTY, FLORIDA CIVIL DIVISION MATRIX FINANCIAL SERVICES CORP, Plaintiff, VS. CASE NO. 2022-CA-000085 DENNIS M. LEWIS A/K/A DENNIS MATTHEW LEWIS F/K/A DENNIS MATTEW LEWIS et al., Defendants, / PLAINTIFF’S MOTION TO_CANCEL AND RESET FORECLOSURE SALE COMES NOW, Plaintiff, MATRIX FINANCIAL SERVICES CORP (“Plaintiff”), by and through undersigned counsel, does hereby file this Motion to Cancel and Reset Foreclosure Sale and states: 1 On July 29, 2023, this Court entered Final Judgment of Foreclosure pursuant to which a foreclosure sale was set for November 2023. 2. The November 2, 2023, sale needs to be cancelled as Plaintiff and Defendant are engaged in loss mitigation. Defendant has been approved for a trial loan modification and has already submitted two payment. 3. Plaintiff respectfully requests that this Court reset the sale for a date no sooner than February 2023. WHEREFORE, Plaintiff respectfully requests that this Court enter an Order cancelling and resetting the foreclosure sale and for such further relief this Court deems just and proper. Dated this 4" day of October 2023. SOKOLOF REMTULLA, PLLC By: /s/ Benjamin D. Ladouceur Benjamin D. Ladouceur, Esq. Florida Bar No.: 73863 Primary e-mail: bladouceur@sokrem.com SOK TEND. CC Electronically Filed Glades Case # 22000085CAMXAX 40/04/2023 01:08:27 PM Secondary e-mail: pleadings(@sokrem.com 6801 Lake Worth Road, Suite 100E Greenacres, Florida 33467 Telephone: 561-507-5252 Facsimile: 561-342-4842 Counsel for Plaintiff CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been filed with the Clerk of Court using the Florida Courts E-Filing Portal, and a copy has been served via E- mail or U.S. Mail to the parties listed below on this 4" day of October 2023. Dennis M. Lewis A/K/A Dennis Matthew Lewis F/K/A Dennis Mattew Lewis, 1497 Muse Road, Labelle, FL 33935, e-mail: Idl-properties@outlook.com Jessica Lewis, 1497 Muse Road, Labelle, FL 33935, e-mail: {dl.properties@outlook.com /s/_ Benjamin D. Ladouceur