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Filing # 31231797 E-Filed 08/24/2015 02:56:41 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
MARIA SOLER, CASE NO.: CACE-15-013152 (02)
Plaintiff,
vs.
MELROSE POINT AT
MONARCH LAKES CONDOMINIUM
ASSOCIATION, INC.,
Defendant.
/
DEFENDANT MELROSE POINT AT MONARCH LAKES CONDOMINIUM
ASSOCIATION INC.’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S COMPLAINT
Defendant, MELROSE POINT AT MONARCH LAKES CONDOMINIUM
ASSOCIATION, INC. (hereinafter “Melrose Point” or the “Association”), pursuant to Rule
1.090(b) of the Florida Rules of Civil Procedure, hereby moves this Court for an
extension of time to file its response to Plaintiff, MARIA SOLER’s Complaint, and in
support thereof states as follows:
1. Plaintiff filed her Complaint against the Association on July 30, 2015 pro-
se, and served same upon the Association on August 3, 2015.
2. The undersigned counsel was very recently retained in this matter, and is
currently in the process of gathering information and investigating the issues and
allegations contained in the Complaint.
3. To that end, the undersigned counsel attempted to contact the pro-se
Plaintiff regarding the Association’s need for additional time to file its response to the
COLE, SCOTT & KISSANE, P.A.
110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT. LAUDERDALE, FLORIDA 33301 (954) 703.3700 (954) 703.3701 FAX
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/24/2015 2:56:42 PM.****CASE NO.: CACE-15-013152 (02)
Plaintiff's Complaint. To date, however, Plaintiff has not responded.
4. Accordingly, the Association respectfully requests a brief 20-day
extension of time, through and including September 13, 2015, to file its response to the
Complaint.
5. This Motion is made in good faith and not for purposes of delay.
CERTIFICATE OF CONFERENCE
The undersigned hereby certifies that she attempted to confer with the pro-se
Plaintiff prior to filing this Motion, in a good faith effort to try to resolve the issues raised
herein. As of the date of the filing of the Motion, however, Plaintiff has been
unresponsive.
-2-
COLE, SCOTT & KISSANE, P.A.
110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT, LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAXCASE NO.: CACE-15-013152 (02)
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing was sent via
U.S. Mail this 24th day of August, 2015 to: Plaintiff, Maria Soler, 1321 St. Tropez Circle
#1004, Weston, Florida 33326, and | electronically filed the foregoing with the Clerk of
Broward County by using the Florida Courts eFiling Portal.
COLE, SCOTT & KISSANE, P.A.
Attorneys for Defendant
110 Tower
110 S.E. 6th Street, Suite 1850
Ft. Lauderdale, Florida 33301
E-Mail: scott.bassman@csklegal.com
tasha.somarriba@csklegal.com
Telephone: 954-703-3703
Facsimile: 954-703-3701
By: _s/ Tasha M. Somarriba
Scott A. Bassman
Florida Bar Number: 232180
Tasha M. Somarriba
Florida Bar Number: 111320
SAB/TMS
\10.150.0.11\casefiles\4044-0418-00\pleading\motion\motion - extension of time to respond to complaint (melrose point),docx
-3-
COLE, SCOTT & KISSANE, P.A.
110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT, LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX
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Filing # 31231797 E-Filed 08/24/2015 02:56:41 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MARIA SOLER, CASE NO.: CACE-15-013152 (02) Plaintiff, vs. MELROSE POINT AT MONARCH LAKES CONDOMINIUM ASSOCIATION, INC., Defendant. / DEFENDANT MELROSE POINT AT MONARCH LAKES CONDOMINIUM ASSOCIATION INC.’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendant, MELROSE POINT AT MONARCH LAKES CONDOMINIUM ASSOCIATION, INC. (hereinafter “Melrose Point” or the “Association”), pursuant to Rule 1.090(b) of the Florida Rules of Civil Procedure, hereby moves this Court for an extension of time to file its response to Plaintiff, MARIA SOLER’s Complaint, and in support thereof states as follows: 1. Plaintiff filed her Complaint against the Association on July 30, 2015 pro- se, and served same upon the Association on August 3, 2015. 2. The undersigned counsel was very recently retained in this matter, and is currently in the process of gathering information and investigating the issues and allegations contained in the Complaint. 3. To that end, the undersigned counsel attempted to contact the pro-se Plaintiff regarding the Association’s need for additional time to file its response to the COLE, SCOTT & KISSANE, P.A. 110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT. LAUDERDALE, FLORIDA 33301 (954) 703.3700 (954) 703.3701 FAX *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/24/2015 2:56:42 PM.****CASE NO.: CACE-15-013152 (02) Plaintiff's Complaint. To date, however, Plaintiff has not responded. 4. Accordingly, the Association respectfully requests a brief 20-day extension of time, through and including September 13, 2015, to file its response to the Complaint. 5. This Motion is made in good faith and not for purposes of delay. CERTIFICATE OF CONFERENCE The undersigned hereby certifies that she attempted to confer with the pro-se Plaintiff prior to filing this Motion, in a good faith effort to try to resolve the issues raised herein. As of the date of the filing of the Motion, however, Plaintiff has been unresponsive. -2- COLE, SCOTT & KISSANE, P.A. 110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT, LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAXCASE NO.: CACE-15-013152 (02) CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail this 24th day of August, 2015 to: Plaintiff, Maria Soler, 1321 St. Tropez Circle #1004, Weston, Florida 33326, and | electronically filed the foregoing with the Clerk of Broward County by using the Florida Courts eFiling Portal. COLE, SCOTT & KISSANE, P.A. Attorneys for Defendant 110 Tower 110 S.E. 6th Street, Suite 1850 Ft. Lauderdale, Florida 33301 E-Mail: scott.bassman@csklegal.com tasha.somarriba@csklegal.com Telephone: 954-703-3703 Facsimile: 954-703-3701 By: _s/ Tasha M. Somarriba Scott A. Bassman Florida Bar Number: 232180 Tasha M. Somarriba Florida Bar Number: 111320 SAB/TMS \10.150.0.11\casefiles\4044-0418-00\pleading\motion\motion - extension of time to respond to complaint (melrose point),docx -3- COLE, SCOTT & KISSANE, P.A. 110 TOWER - 110 SE. 6TH STREET, SUITE 1850 - FT, LAUDERDALE, FLORIDA 33301 (954) 703-3700 (954) 703-3701 FAX