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Filing # 41304276 E-Filed 05/10/2016 03:02:49 PM
IN THE CIRCUIT COURT OF THE 0 JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE15012974 (11)
WELLS FARGO BANK, NA,
Plaintiff,
vs.
GEORGE T. GOODMAN AND IRMA
OLIVARES, et. al.
Defendants.
DEFENDANTS’ MOTION FOR CONTINUANCE OF
TRIAL SCHEDULED FOR JUNE 13, 2016
COME NOW, Defendants, GEORGE T. GOODMAN AND IRMA OLIVARES, by and
through undersigned counsel, hereby file this Motion for Continuance of Trial scheduled for June
13, 2016, and as grounds in support thereof state as follows:
1. On July 17, 2015, Plaintiff, WELLS FARGO BANK, NA [herein referred to as
Plaintiff], filed a Mortgage Foreclosure Complaint.
2. On March 25, 2016, the Honorable Joel Lazarus entered an Order Setting Non-Jury
Foreclosure Trial and Pretrial Procedures.
3. Pursuant to the Court’s Order, trial in this matter has been scheduled for June 13,
2016.
4, The Defendants are requesting that the trial scheduled for June 13, 2016 be
continued, as Defendants’ trial counsel will be unable to appear at the trial presently
scheduled for June 13, 2016.
5. Loan Lawyers, LLC will be closed, and all counsel will be unavailable, on
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/10/2016 3:02:49 PM.****June 13, 2016, in religious observance of the Jewish Holiday, Shavuot.
6. Loan Lawyers, LLC is an Orthodox Jewish Law Firm, and work is not permitted
during Shavuot.
7. For this reason, undersigned counsel is requesting that the trial scheduled for June
13, 2016 be continued, and reset for a date that the Court determines to be
appropriate.
8. No parties’ interest will be prejudiced, should this Court grant Defendant’s Motion
for Continuance of Trial.
9. This Motion for Continuance is being filed in good faith.
10. This Motion is not being filed to hinder or delay the judicial process.
WHEREFORE, the Defendants, GEORGE T. GOODMAN AND IRMA OLIVARES,
respectfully request that this Honorable Court grant Defendants’ Motion for Continuance of Trial.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on May 10, 2016, I electronically filed the foregoing document
with the Clerk of the Court using the Florida Courts E-Filing Portal. I also certify that the foregoing
document is being served on counsel on the Service List below via e-mail generated by the E-Portal
system or by U.S. Mail to any party that has not designated an e-mail address for service.
Respectfully Submitted,
/s/ Chase E. Jenkins
Michael A. Citron, Esq.
Florida Bar No. 94261
LOAN LAWYERS, LLC
Attorneys for Defendants
2150 S. Andrews Ave, 2" Floor
Fort Lauderdale, FL 33316
Telephone: (954) 523-4357
Facsimile: (954) 581-2786
chase@fight13.com
efile@fight13.com
FC-772068SERVICE LIST
WELLS FARGO BANK, NA
v.
GEORGE T. GOODMAN AND IRMA OLIVARES
Case No.: CACE15012974 (11)
Aldridge Pite, LLP
1615 South Congress Avenue
Suite 200
Delray Beach, FL 33445
servicemail@aldridgepite.com; DEF AMTRUST BANK: notice@kahaneandassociates.com
FC-772068
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Filing # 41304276 E-Filed 05/10/2016 03:02:49 PM IN THE CIRCUIT COURT OF THE 0 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE15012974 (11) WELLS FARGO BANK, NA, Plaintiff, vs. GEORGE T. GOODMAN AND IRMA OLIVARES, et. al. Defendants. DEFENDANTS’ MOTION FOR CONTINUANCE OF TRIAL SCHEDULED FOR JUNE 13, 2016 COME NOW, Defendants, GEORGE T. GOODMAN AND IRMA OLIVARES, by and through undersigned counsel, hereby file this Motion for Continuance of Trial scheduled for June 13, 2016, and as grounds in support thereof state as follows: 1. On July 17, 2015, Plaintiff, WELLS FARGO BANK, NA [herein referred to as Plaintiff], filed a Mortgage Foreclosure Complaint. 2. On March 25, 2016, the Honorable Joel Lazarus entered an Order Setting Non-Jury Foreclosure Trial and Pretrial Procedures. 3. Pursuant to the Court’s Order, trial in this matter has been scheduled for June 13, 2016. 4, The Defendants are requesting that the trial scheduled for June 13, 2016 be continued, as Defendants’ trial counsel will be unable to appear at the trial presently scheduled for June 13, 2016. 5. Loan Lawyers, LLC will be closed, and all counsel will be unavailable, on *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/10/2016 3:02:49 PM.****June 13, 2016, in religious observance of the Jewish Holiday, Shavuot. 6. Loan Lawyers, LLC is an Orthodox Jewish Law Firm, and work is not permitted during Shavuot. 7. For this reason, undersigned counsel is requesting that the trial scheduled for June 13, 2016 be continued, and reset for a date that the Court determines to be appropriate. 8. No parties’ interest will be prejudiced, should this Court grant Defendant’s Motion for Continuance of Trial. 9. This Motion for Continuance is being filed in good faith. 10. This Motion is not being filed to hinder or delay the judicial process. WHEREFORE, the Defendants, GEORGE T. GOODMAN AND IRMA OLIVARES, respectfully request that this Honorable Court grant Defendants’ Motion for Continuance of Trial. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on May 10, 2016, I electronically filed the foregoing document with the Clerk of the Court using the Florida Courts E-Filing Portal. I also certify that the foregoing document is being served on counsel on the Service List below via e-mail generated by the E-Portal system or by U.S. Mail to any party that has not designated an e-mail address for service. Respectfully Submitted, /s/ Chase E. Jenkins Michael A. Citron, Esq. Florida Bar No. 94261 LOAN LAWYERS, LLC Attorneys for Defendants 2150 S. Andrews Ave, 2" Floor Fort Lauderdale, FL 33316 Telephone: (954) 523-4357 Facsimile: (954) 581-2786 chase@fight13.com efile@fight13.com FC-772068SERVICE LIST WELLS FARGO BANK, NA v. GEORGE T. GOODMAN AND IRMA OLIVARES Case No.: CACE15012974 (11) Aldridge Pite, LLP 1615 South Congress Avenue Suite 200 Delray Beach, FL 33445 servicemail@aldridgepite.com; DEF AMTRUST BANK: notice@kahaneandassociates.com FC-772068