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Filing # 31923021 E-Filed 09/10/2015 04:40:17 PM
IN THE CIRCUIT COURT OF THE
17" JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO.: CACE15012974 (11)
WELLS FARGO BANK, NA,
Plaintiff,
vs.
GEORGE T. GOODMAN, et. al.
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO COMPLAINT
COMES NOW, Defendant, GEORGE T. GOODMAN, by and through undersigned
counsel, and pursuant to Florida Rules of Civil Procedure 1.140, hereby files this Motion for
Extension of Time to Respond to Plaintiff's Complaint, and as grounds in support thereof states
as follows:
i. On July 17, 2015, Plaintiff, WELLS FARGO BANK, NA [herein referred to as
WELLS FARGO BANK, NA], filed a Mortgage Foreclosure Complaint.
2. That Defendant’s responses to Plaintiff's Complaint are due on August 25, 2015.
3. As of September 3, 2015, undersigned counsel for Defendant, GEORGE T.
GOODMAN has been retained and has filed a Notice of Appearance, said notice is
attached hereto as Exhibit “A”
[THIS SPACE WAS INTENTIONALLY LEFT BLANK]
FC-772068 CACE15012974 (11)
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/10/2015 4:40:17 PM.****4. Defendant’s counsel requires additional time to prepare responses to Plaintiff's
Complaint. This request is not being filed to hinder or delay the judicial process.
WHEREFORE, the Defendant, GEORGE T. GOODMAN, respectfully requests an
extension to file a response to the Plaintiff's Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded
electronic mail, on this ib day of September, 2015, to (servicemail@aldridgepite.com):
Gweneth M. Brimm, Esq., Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach,
Florida 33445. Fax: (561)392-6965.
LOAN LAWYERS, LLC
Attorneys for Defendant
2150 South Andrews Ave, 2" Floor
Fort Lauderdale, FL 33316
Telephone: (954) 523-4357
Faggfmile, (954) 581-2786
By:
LAURX L. HOY, ESQ.
FBN 05902
SONJA-LUCIENNE CAJUSTE, ESQ.
BN 102983
ICHAEL A. CITRON, ESQ.
‘7 FBN 105083
MATIS H. ABARBANEL, ESQ.
FBN 130435
MATTHEW D. BAVARO ESQ.
FBN 175821
FC-772068 CACE15012974 (11)Filing # 31901333 E-Filed 09/10/2015 01:35:08 PM
IN THE CIRCUIT COURT OF THE
17 JUDICIAL CIRCUIT IN ANE
FOR BROWARD COUNTY, FI
CASE NO.: CACE1501297
WELLS FARGO BANK, NA,
Piaintiff,
VS.
GEORGE T. GOODMAN, et. al.
Defendant,
/
NOTICE OF APPEARANCE AND DESIGNATION OF E-MAIL ADDRESSES
COMES NOW, MICHAEL A. CITRON, ESQ. and hereby gives notice that he is
counsel of record for Defendant, GEORGE T. GOODMAN, and requests that all pleadings,
documents, and correspondence be directed to him.
Pursuant to Rule of Judicial Administration 2.516, please serve all future filings by ¢-
mailing Michael A. Citron at Michael@floridaloanlawyers.com and by e-mailing
service@floridaloanlawyers.com.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a te and correct copy of the foregoing was forwarded
icemail@aldridgepite.com):
electronic mail, on this Lo day of September, 2015, to (se
Gweneth M. Brimm, Esq., Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach,
Florida 33445. Fax: (561)392-6965.
LOAN LAWYERS, LLC
Attorneys for Defendant
2150 South Andrews Ave, 2" Floor
Fort Lauderdale, FL 33316
Telephone: (954) 523-4357
Faesjmile:
By:
MICHAEL A,
FBN: 105083
FC-772068
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Filing # 31923021 E-Filed 09/10/2015 04:40:17 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE15012974 (11) WELLS FARGO BANK, NA, Plaintiff, vs. GEORGE T. GOODMAN, et. al. Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT COMES NOW, Defendant, GEORGE T. GOODMAN, by and through undersigned counsel, and pursuant to Florida Rules of Civil Procedure 1.140, hereby files this Motion for Extension of Time to Respond to Plaintiff's Complaint, and as grounds in support thereof states as follows: i. On July 17, 2015, Plaintiff, WELLS FARGO BANK, NA [herein referred to as WELLS FARGO BANK, NA], filed a Mortgage Foreclosure Complaint. 2. That Defendant’s responses to Plaintiff's Complaint are due on August 25, 2015. 3. As of September 3, 2015, undersigned counsel for Defendant, GEORGE T. GOODMAN has been retained and has filed a Notice of Appearance, said notice is attached hereto as Exhibit “A” [THIS SPACE WAS INTENTIONALLY LEFT BLANK] FC-772068 CACE15012974 (11) *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 9/10/2015 4:40:17 PM.****4. Defendant’s counsel requires additional time to prepare responses to Plaintiff's Complaint. This request is not being filed to hinder or delay the judicial process. WHEREFORE, the Defendant, GEORGE T. GOODMAN, respectfully requests an extension to file a response to the Plaintiff's Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was forwarded electronic mail, on this ib day of September, 2015, to (servicemail@aldridgepite.com): Gweneth M. Brimm, Esq., Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach, Florida 33445. Fax: (561)392-6965. LOAN LAWYERS, LLC Attorneys for Defendant 2150 South Andrews Ave, 2" Floor Fort Lauderdale, FL 33316 Telephone: (954) 523-4357 Faggfmile, (954) 581-2786 By: LAURX L. HOY, ESQ. FBN 05902 SONJA-LUCIENNE CAJUSTE, ESQ. BN 102983 ICHAEL A. CITRON, ESQ. ‘7 FBN 105083 MATIS H. ABARBANEL, ESQ. FBN 130435 MATTHEW D. BAVARO ESQ. FBN 175821 FC-772068 CACE15012974 (11)Filing # 31901333 E-Filed 09/10/2015 01:35:08 PM IN THE CIRCUIT COURT OF THE 17 JUDICIAL CIRCUIT IN ANE FOR BROWARD COUNTY, FI CASE NO.: CACE1501297 WELLS FARGO BANK, NA, Piaintiff, VS. GEORGE T. GOODMAN, et. al. Defendant, / NOTICE OF APPEARANCE AND DESIGNATION OF E-MAIL ADDRESSES COMES NOW, MICHAEL A. CITRON, ESQ. and hereby gives notice that he is counsel of record for Defendant, GEORGE T. GOODMAN, and requests that all pleadings, documents, and correspondence be directed to him. Pursuant to Rule of Judicial Administration 2.516, please serve all future filings by ¢- mailing Michael A. Citron at Michael@floridaloanlawyers.com and by e-mailing service@floridaloanlawyers.com. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a te and correct copy of the foregoing was forwarded icemail@aldridgepite.com): electronic mail, on this Lo day of September, 2015, to (se Gweneth M. Brimm, Esq., Aldridge Pite, LLP, 1615 South Congress Avenue, Delray Beach, Florida 33445. Fax: (561)392-6965. LOAN LAWYERS, LLC Attorneys for Defendant 2150 South Andrews Ave, 2" Floor Fort Lauderdale, FL 33316 Telephone: (954) 523-4357 Faesjmile: By: MICHAEL A, FBN: 105083 FC-772068