On November 16, 2023 a
DEF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO VERIFIED COMPLAINT TO FORECLOSE MORTGAGE
was filed
involving a dispute between
Arnold Ritchie Gilmore Decease,
M And T Bank,
and
Gilmore, Eric Ritchie,
Gilmore, Gary Earle,
Kildahl, Kim A,
Nelson, Linda Denise,
Of Arnold Ritchie Gilmore, Lin,
Pagan, Heather Yvonne Colon,
Possession 1, Unknown Party In,
Possession 2, Unknown Party In,
for Circuit Civil 3-C
in the District Court of Highlands County.
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Filing # 188791032 E-Filed 12/28/2023 03:41:38 PM
IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT
IN AND FOR HIGHLANDS COUNTY, FLORIDA
CIVIL ACTION
M&T BANK, CASE NO.: 2023CA000708
Plaintiff,
Vv.
LINDA DENISE NELSON; et al.,
Defendants.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO VERIFIED COMPLAINT TO FORECLOSE MORTGAGE
Defendant, Linda Nelson, (“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, M&T Bank, (“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 Highlands Case # 23000708GCAXMX 12/28/2023 03:41:38 PM
Complaint and for such other and further relief as this Court deems appropriate
Dated: December 28, 2023.
KYLE & KYLE LAW
Attorneys for Defendant
Orlando, FL 32803
(407) 487-8820
john@kyleandkylelaw.com
tina@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 December 28, 2023, to:
Tiffany & Bosco, PA
1201 S. Orlando Ave, Ste 430
Winter Park, FL 32789
floridaservice@tblaw.com
Attorney for Plaintiff
4s/ John Lara
John Lara, Esq.
Document Filed Date
December 28, 2023
Case Filing Date
November 16, 2023
Category
Circuit Civil 3-C
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Filing # 188791032 E-Filed 12/28/2023 03:41:38 PM IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT IN AND FOR HIGHLANDS COUNTY, FLORIDA CIVIL ACTION M&T BANK, CASE NO.: 2023CA000708 Plaintiff, Vv. LINDA DENISE NELSON; et al., Defendants. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO VERIFIED COMPLAINT TO FORECLOSE MORTGAGE Defendant, Linda Nelson, (“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, M&T Bank, (“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 Highlands Case # 23000708GCAXMX 12/28/2023 03:41:38 PM Complaint and for such other and further relief as this Court deems appropriate Dated: December 28, 2023. KYLE & KYLE LAW Attorneys for Defendant Orlando, FL 32803 (407) 487-8820 john@kyleandkylelaw.com tina@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 December 28, 2023, to: Tiffany & Bosco, PA 1201 S. Orlando Ave, Ste 430 Winter Park, FL 32789 floridaservice@tblaw.com Attorney for Plaintiff 4s/ John Lara John Lara, Esq.