On July 30, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
Pingora Loan Servicing Llc,
and
Mailands Of Tamarac Section Eight Assn Inc,
Rackin, Frederick E,
Rackin, Gladys M,
for Real Prop Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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Filing # 30964261 E-Filed 08/17/2015 04:57:41 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: 062015CA013575
PINGORA LOAN SERVICING, LLC
Plaintiff,
v.
FREDERICK E. RACKIN AND GLADYS
M. RACKIN, et al,
Defendants.
Sey
MOTION FOR EXTENSION OF TIME TO SERVE A
RESPONSE AND/OR DIRECT MOTIONS TO PLAINTIFF'S COMPLAINT
COMES NOW THE Defendant(s), FREDERICK E. RACKIN AND GLADYS M.
RACKIN (hereinafter referred to as “Defendant”), by and through its undersigned counsel and
makes this its Motion for an Extension of Time within which to serve a response and/or direct
Motions to Plaintiff's Complaint and in furtherance thereof would state as follows:
1. That Plaintiff filed its Complaint with the Court on July 30, 2015.
2. That Plaintiff served its Complaint upon the Defendant on or about August 10, 2015.
3. That a response from Defendant to Plaintiffs Complaint is due on or about August 31,
2015.
4. That the Defendant is in need of a forty-five (45) day extension, to wit: October 15,
2015 within which to respond and/or direct Motions to Plaintiff's Complaint.
5. That this Motion is filed in good faith and without any intention to delay or prejudice
the parties.
6. That simultaneously with the service of this Motion for Extension of Time, the
undersigned is contacting counsel for the Plaintiff to determine whether an Agreed Order can be
entered on this Motion.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/17/2015 4:57:41 PM.****WHEREFORE the Defendant moves this Honorable Court for an order extending the
time within which to respond and/or direct Motions to Plaintiffs Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Mail,
pursuant to Fla. R. Civ. P. Rule 2.516 or, if service by E-Mail is not permitted under such Rule, via U.S.
Mail on this 17th day of August, 2015 to the parties on the attached Service List.
THE HERMAN LAW GROUP, P.A.
By: __/S/ Bruce K. Herman
Bruce K. Herman, Esq. (Fla. Bar No.260622)
Service by E-Mail: Service@THLGlaw.com
1401 E. Broward Blvd, Suite 206
Ft. Lauderdale, FL 33301
Tel: 954-762-2555
Fax: 954-762-2554
SERVICE LIST
Case No.: 062015CA013575
David Morales, Esq
Millennium Partners
Attorney for Plaintiff
Email Service: service@millenniumpartners.net
Document Filed Date
August 17, 2015
Case Filing Date
July 30, 2015
Category
Real Prop Homestead Res Fore - >$50K - <$250,000
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Filing # 30964261 E-Filed 08/17/2015 04:57:41 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: 062015CA013575 PINGORA LOAN SERVICING, LLC Plaintiff, v. FREDERICK E. RACKIN AND GLADYS M. RACKIN, et al, Defendants. Sey MOTION FOR EXTENSION OF TIME TO SERVE A RESPONSE AND/OR DIRECT MOTIONS TO PLAINTIFF'S COMPLAINT COMES NOW THE Defendant(s), FREDERICK E. RACKIN AND GLADYS M. RACKIN (hereinafter referred to as “Defendant”), by and through its undersigned counsel and makes this its Motion for an Extension of Time within which to serve a response and/or direct Motions to Plaintiff's Complaint and in furtherance thereof would state as follows: 1. That Plaintiff filed its Complaint with the Court on July 30, 2015. 2. That Plaintiff served its Complaint upon the Defendant on or about August 10, 2015. 3. That a response from Defendant to Plaintiffs Complaint is due on or about August 31, 2015. 4. That the Defendant is in need of a forty-five (45) day extension, to wit: October 15, 2015 within which to respond and/or direct Motions to Plaintiff's Complaint. 5. That this Motion is filed in good faith and without any intention to delay or prejudice the parties. 6. That simultaneously with the service of this Motion for Extension of Time, the undersigned is contacting counsel for the Plaintiff to determine whether an Agreed Order can be entered on this Motion. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/17/2015 4:57:41 PM.****WHEREFORE the Defendant moves this Honorable Court for an order extending the time within which to respond and/or direct Motions to Plaintiffs Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Mail, pursuant to Fla. R. Civ. P. Rule 2.516 or, if service by E-Mail is not permitted under such Rule, via U.S. Mail on this 17th day of August, 2015 to the parties on the attached Service List. THE HERMAN LAW GROUP, P.A. By: __/S/ Bruce K. Herman Bruce K. Herman, Esq. (Fla. Bar No.260622) Service by E-Mail: Service@THLGlaw.com 1401 E. Broward Blvd, Suite 206 Ft. Lauderdale, FL 33301 Tel: 954-762-2555 Fax: 954-762-2554 SERVICE LIST Case No.: 062015CA013575 David Morales, Esq Millennium Partners Attorney for Plaintiff Email Service: service@millenniumpartners.net