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Filing # 31504106 E-Filed 08/31/2015 12:50:20 PM
IN THE CIRCUIT COURT OF THE SEVENTHEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BANK OF AMERICA, N.A.,
Plaintiff, CASE NO.: CACE15-013633
v.
RUTH JOSEPH A/K/A JOSEPH RUTH
SPOUSE OF RUTH JOSEPH A/K/A JOSEPH RUTH
HOUSING FINANCE AUTHORITY OF LEE COUNTY
FLORIDA, STATE OF FLORIDA, BROWARD
COUNTY, BOARD OF COUNTY COMMISSIONERS OF
BROWARD COUNTY, FLORIDA; UNKNOWN TENANT #1
UNKNOWN TENANT #2, et al.,
Defendants
/
MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT
COMES NOW, Defendant, Ruth Joseph , by and through undersigned counsel
and pursuant to Rules 1.090 and 1.140 of Florida Rules of Civil Procedure, hereby files
the Motion for Extension of Time to Respond to the Complaint. And in support thereof
states as follows:
1. Plaintiff caused Defendants to be served with process on August 10, 2015.
2. Pursuant to Rule 1.140 of Florida Rules of Civil Procedure, Defendants had until
August 31,2 015 to file a response to the Complaint.
3. Defendants are unable to comprehensively respond to the Complaint without first
verifying the material terms of the debt that is the subject of this collections action.
4. The matter is in its infancy. No other motions are pending, and no discovery is
outstanding or owed. A copy of Defendants verification of Debt pursuant to Fair Debt
Collection Practices Act is annexed hereto as Exhibit 1.
Page 1
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/31/2015 12:50:21 PM.****5. Defendants seek said extension in good faith and not to unnecessarily delay the
action.
WHEREFORE Defendants by and through undersigned counsel respectfully
requests this Court enter an order granting and extension of forty-five (45) days or fifteen
days from the date Plaintiff's response to Defendants’ request for verification of debt
pursuant to 15 U.S.C. § 1692, and any other relief this Court deems just and proper.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing with mailed to the
Plaintiff's attorney, Antonio Caula, Esq., Frenkel Lambert Weiss Weisman & Gordon,
LLP., fleservice@flwlaw.com via eservice on this 31“ day of August 2015.
Owei Z. Belleh, Esq.
Attorney for Defendants
BROWN & BELLEH, PLLC.
Causeway Square
1801 NE 123" Street Suite 409
North Miami, Florida 33181
Tel/Fax: 888.450.7999
Eservice: eservice@bellehlaw.com
owei @bellehlaw.co
m1
By: __/s/ Owei Z. Belleh
Owei Z. Belleh
FBN.: 617598
Page 2IN THE CIRCUIT COURT OF THE SEVENTHEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
BANK OF AMERICA, N.A.,
Plaintiff, CASE NO.: CACE15-013633
v.
RUTH JOSEPH A/K/A JOSEPH RUTH
SPOUSE OF RUTH JOSEPH A/K/A JOSEPH RUTH
HOUSING FINANCE AUTHORITY OF LEE COUNTY
FLORIDA, STATE OF FLORIDA, BROWARD
COUNTY, BOARD OF COUNTY COMMISSIONERS OF
BROWARD COUNTY, FLORIDA; UNKNOWN TENANT #1
UNKNOWN TENANT #2, et al.,
Defendants
/
VERIFICATION OF DEBT
COMES NOW, Defendants, Ruth Joseph, (hereinafter the “Defendants”), by and
through undersigned counsel, hereby files this request for verification of debt pursuant to
the Fair Debt Collection and Practices Act, 15 U.S.C. § 1692, as Amended, hereby
disputes the validity of the debt alleged by Plaintiff, CHASE HOME FINANCE, LLC,
and requests written verification within Thirty (30) days of the notice of this request.
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing with mailed to the
Plaintiff's attorney, Antonio Caula, Esq., Frenkel Lambert Weiss Weisman & Gordon,
LLP, fleservice@flwlaw.com via eservice on this 31“ day of August 2015.
Owei Z. Belleh, Esq.
Attorney for Defendants
BROWN & BELLEH, PLLC.
Causeway Square
Page 3Page 4
1801 NE 123" Street Suite 409
North Miami, Florida 33181
Tel/Fax: 888.450.7999
Eservice: eservice@bellehlaw.com
By: __/s/ Owei Z. Belleh
Owei Z. Belleh
FBN.: 617598
Preview
Filing # 31504106 E-Filed 08/31/2015 12:50:20 PM IN THE CIRCUIT COURT OF THE SEVENTHEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BANK OF AMERICA, N.A., Plaintiff, CASE NO.: CACE15-013633 v. RUTH JOSEPH A/K/A JOSEPH RUTH SPOUSE OF RUTH JOSEPH A/K/A JOSEPH RUTH HOUSING FINANCE AUTHORITY OF LEE COUNTY FLORIDA, STATE OF FLORIDA, BROWARD COUNTY, BOARD OF COUNTY COMMISSIONERS OF BROWARD COUNTY, FLORIDA; UNKNOWN TENANT #1 UNKNOWN TENANT #2, et al., Defendants / MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT COMES NOW, Defendant, Ruth Joseph , by and through undersigned counsel and pursuant to Rules 1.090 and 1.140 of Florida Rules of Civil Procedure, hereby files the Motion for Extension of Time to Respond to the Complaint. And in support thereof states as follows: 1. Plaintiff caused Defendants to be served with process on August 10, 2015. 2. Pursuant to Rule 1.140 of Florida Rules of Civil Procedure, Defendants had until August 31,2 015 to file a response to the Complaint. 3. Defendants are unable to comprehensively respond to the Complaint without first verifying the material terms of the debt that is the subject of this collections action. 4. The matter is in its infancy. No other motions are pending, and no discovery is outstanding or owed. A copy of Defendants verification of Debt pursuant to Fair Debt Collection Practices Act is annexed hereto as Exhibit 1. Page 1 ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/31/2015 12:50:21 PM.****5. Defendants seek said extension in good faith and not to unnecessarily delay the action. WHEREFORE Defendants by and through undersigned counsel respectfully requests this Court enter an order granting and extension of forty-five (45) days or fifteen days from the date Plaintiff's response to Defendants’ request for verification of debt pursuant to 15 U.S.C. § 1692, and any other relief this Court deems just and proper. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing with mailed to the Plaintiff's attorney, Antonio Caula, Esq., Frenkel Lambert Weiss Weisman & Gordon, LLP., fleservice@flwlaw.com via eservice on this 31“ day of August 2015. Owei Z. Belleh, Esq. Attorney for Defendants BROWN & BELLEH, PLLC. Causeway Square 1801 NE 123" Street Suite 409 North Miami, Florida 33181 Tel/Fax: 888.450.7999 Eservice: eservice@bellehlaw.com owei @bellehlaw.co m1 By: __/s/ Owei Z. Belleh Owei Z. Belleh FBN.: 617598 Page 2IN THE CIRCUIT COURT OF THE SEVENTHEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA BANK OF AMERICA, N.A., Plaintiff, CASE NO.: CACE15-013633 v. RUTH JOSEPH A/K/A JOSEPH RUTH SPOUSE OF RUTH JOSEPH A/K/A JOSEPH RUTH HOUSING FINANCE AUTHORITY OF LEE COUNTY FLORIDA, STATE OF FLORIDA, BROWARD COUNTY, BOARD OF COUNTY COMMISSIONERS OF BROWARD COUNTY, FLORIDA; UNKNOWN TENANT #1 UNKNOWN TENANT #2, et al., Defendants / VERIFICATION OF DEBT COMES NOW, Defendants, Ruth Joseph, (hereinafter the “Defendants”), by and through undersigned counsel, hereby files this request for verification of debt pursuant to the Fair Debt Collection and Practices Act, 15 U.S.C. § 1692, as Amended, hereby disputes the validity of the debt alleged by Plaintiff, CHASE HOME FINANCE, LLC, and requests written verification within Thirty (30) days of the notice of this request. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing with mailed to the Plaintiff's attorney, Antonio Caula, Esq., Frenkel Lambert Weiss Weisman & Gordon, LLP, fleservice@flwlaw.com via eservice on this 31“ day of August 2015. Owei Z. Belleh, Esq. Attorney for Defendants BROWN & BELLEH, PLLC. Causeway Square Page 3Page 4 1801 NE 123" Street Suite 409 North Miami, Florida 33181 Tel/Fax: 888.450.7999 Eservice: eservice@bellehlaw.com By: __/s/ Owei Z. Belleh Owei Z. Belleh FBN.: 617598