On July 30, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
U.S. Bank National Association,
and
Carla P Anthony-Watson,
Honeyplace Homeowners Association Inc,
Mortgage Electronic Registry Systems, Inc,
Watson, Calvin J,
for Real Prop Non-Homestead Res Fore =/>$250,000
in the District Court of Broward County.
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Filing # 31935394 E-Filed 09/11/2015 09:22:24 AM
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO.: CACE15013618 (11)
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR MASTR ASSET BACKED
SECURITIES TRUST 2006-WMC4 MORTGAGE
PASS-THROUGH CERTIFICATES SERIES
2006-WMC4
Plaintiff,
vs.
CALVIN J. WATSON a/k/a CALVIN JOSEPH WATSON
and CARLA P. ANTHONY-WATSON, et al.,
Defendant(s). :
MOTION TO ENLARGE TIME TO FILE RESPONSE
The Defendants. CALVIN J. WATSON a/k/a CALVIN JOSEPH WATSON and CARLA P.
ANTHONY-WATSON, move pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure for an
extension of time to file a responsive pleading and as grounds therefore would state as follows:
1. Counsel has just received a copy of the complaint from the Defendants and requires
additional time to review the matter and file all appropriate responses to the Complaint.
Nn
Counsel requests this Court grant Defendants an additional thirty (30) days after the entry
of an Order on this Motion to respond to Plaintiff's Complaint.
There would be no prejudice to any of the parties by the granting of relief requested and this
we
Motion to Enlarge Time is not brought for purpose of delay.
WHEREFORE, the Defendants request the aforesaid relief together with such other and further
relief as this Court would deem just and proper.
CERTIFICATE OF SERVICE
I CERTIFY that a copy of the foregoing was served on September 11, 2015 to all parties on the
list to receive e-mail service for this case via the Florida Courts E-Filing Portal (which is incorporated
herein by reference).
C. Anthony Rumore, P.A.
Attorney for Defendants
515 Southwest Ist Avenue
Fort Lauderdale, FL 33301
PH: 954-942-2414 / FX: 954-942-2415
Service email: pleadings‘@ rmorclay.com
Hearing coordination: laprea @rumorela\y com
aa
f
ae 4
By: = é even
[ ] C. Anthony Rumore, FL Bar No.: 133388
[X] Steven R. Serra, FL Bar No.: 132322
[ ] Leigh S. Jocelyn, FL Bar No.: 111561
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/11/2015 9:22:24 AM.****
Document Filed Date
September 11, 2015
Case Filing Date
July 30, 2015
Category
Real Prop Non-Homestead Res Fore =/>$250,000
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Filing # 31935394 E-Filed 09/11/2015 09:22:24 AM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE15013618 (11) U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR MASTR ASSET BACKED SECURITIES TRUST 2006-WMC4 MORTGAGE PASS-THROUGH CERTIFICATES SERIES 2006-WMC4 Plaintiff, vs. CALVIN J. WATSON a/k/a CALVIN JOSEPH WATSON and CARLA P. ANTHONY-WATSON, et al., Defendant(s). : MOTION TO ENLARGE TIME TO FILE RESPONSE The Defendants. CALVIN J. WATSON a/k/a CALVIN JOSEPH WATSON and CARLA P. ANTHONY-WATSON, move pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure for an extension of time to file a responsive pleading and as grounds therefore would state as follows: 1. Counsel has just received a copy of the complaint from the Defendants and requires additional time to review the matter and file all appropriate responses to the Complaint. Nn Counsel requests this Court grant Defendants an additional thirty (30) days after the entry of an Order on this Motion to respond to Plaintiff's Complaint. There would be no prejudice to any of the parties by the granting of relief requested and this we Motion to Enlarge Time is not brought for purpose of delay. WHEREFORE, the Defendants request the aforesaid relief together with such other and further relief as this Court would deem just and proper. CERTIFICATE OF SERVICE I CERTIFY that a copy of the foregoing was served on September 11, 2015 to all parties on the list to receive e-mail service for this case via the Florida Courts E-Filing Portal (which is incorporated herein by reference). C. Anthony Rumore, P.A. Attorney for Defendants 515 Southwest Ist Avenue Fort Lauderdale, FL 33301 PH: 954-942-2414 / FX: 954-942-2415 Service email: pleadings‘@ rmorclay.com Hearing coordination: laprea @rumorela\y com aa f ae 4 By: = é even [ ] C. Anthony Rumore, FL Bar No.: 133388 [X] Steven R. Serra, FL Bar No.: 132322 [ ] Leigh S. Jocelyn, FL Bar No.: 111561 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/11/2015 9:22:24 AM.****