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Filing # 31245368 E-Filed 08/24/2015 04:38:32 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: CACE 15 012736(11)
NEW YORK COMMUNITY BANK,
Plaintiff,
v.
SAM K. BAIK and CHANG S. BAIK, et
al.,
Defendants.
/
MOTION FOR ENLARGEMENT OF TIME
The Defendants, SAM K. BAIK and CHANG S. BAIK, by and through their
undersigned attorneys, hereby move this Court for an Enlargement of Time to respond
to the Complaint, as follows:
1. This is a Mortgage Foreclosure action that, by its nature, has complex and
intricate details which can only be obtained through receipt of additional documentation,
yet to be provided by the Plaintiff.
2. The Plaintiff served their Complaint for Mortgage Foreclosure in the above
action on August 5, 2015.
3. A Response to the Mortgage Foreclosure Complaint is due on or before
August 25, 2015.
4. The undersigned have submitted a Request for Production and
Interrogatories that were served on the Plaintiff on August 24, 2015.
THE TICKTIN LAW GROUP, P.A.
600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610
TELEPHONE: (954) 570-6757
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/24/2015 4:38:32 PM.****5. Pending the receipt of the above-referenced documents, the undersigned
will then be able to formulate a more detailed response to the Mortgage Foreclosure
Complaint.
6. Due to the complex nature of this foreclosure proceeding and the pending
Discovery, the undersigned needs additional time to properly respond to the Complaint.
7. This Motion is not being made for improper delay or for any other improper
purpose; rather this Motion is being made in an effort to file an informed response to
said Complaint.
Wherefore, the Defendants ask for an enlargement of time to serve their
Response to the Complaint.
DESIGNATION OF EMAIL ADDRESS(ES) FOR SERVICE
(Pursuant to Rule 2.516 Fla. R. Jud. Admin.)
The undersigned attorneys of The Ticktin Law Group, P.A., hereby designate the
following Email Address(es) for service in the above styled matter. Service shall be
complete upon emailing to the following email address(es) in this Designation, provided
that the provisions of Rule 2.516 are followed.
Serv548@LegalBrains.com
SERVICE IS TO BE MADE TO EACH AND EVERY EMAIL ADDRESS
LISTED IN THIS DESIGNATION AND TO NO OTHERS.
2
THE TICKTIN LAW GROUP, P.A.
600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610
TELEPHONE: (954) 570-6757CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
emailed this 24" day of August 2015, to ROBERT L. CHAPMAN, ESQUIRE,
rchapman@sbwiegal.com, Sivyer, Barlow & Watson, P.A., Attorneys for the Plaintiff,
401 East Jackson Street, Suite 2225, Tampa, Florida 33602.
THE TICKTIN LAW GROUP, P.A.
600 West Hillsboro Boulevard
Suite 220
Deerfield Beach, Florida 33441-1610
Telephone: (954) 570-6757
/s/ Anthony J. Badway
ANTHONY J. BADWAY
Florida Bar No. 115321
Our Matter No.: 15-1012
3
THE TICKTIN LAW GROUP, P.A.
600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610
TELEPHONE: (954) 570-6757
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Filing # 31245368 E-Filed 08/24/2015 04:38:32 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: CACE 15 012736(11) NEW YORK COMMUNITY BANK, Plaintiff, v. SAM K. BAIK and CHANG S. BAIK, et al., Defendants. / MOTION FOR ENLARGEMENT OF TIME The Defendants, SAM K. BAIK and CHANG S. BAIK, by and through their undersigned attorneys, hereby move this Court for an Enlargement of Time to respond to the Complaint, as follows: 1. This is a Mortgage Foreclosure action that, by its nature, has complex and intricate details which can only be obtained through receipt of additional documentation, yet to be provided by the Plaintiff. 2. The Plaintiff served their Complaint for Mortgage Foreclosure in the above action on August 5, 2015. 3. A Response to the Mortgage Foreclosure Complaint is due on or before August 25, 2015. 4. The undersigned have submitted a Request for Production and Interrogatories that were served on the Plaintiff on August 24, 2015. THE TICKTIN LAW GROUP, P.A. 600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610 TELEPHONE: (954) 570-6757 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/24/2015 4:38:32 PM.****5. Pending the receipt of the above-referenced documents, the undersigned will then be able to formulate a more detailed response to the Mortgage Foreclosure Complaint. 6. Due to the complex nature of this foreclosure proceeding and the pending Discovery, the undersigned needs additional time to properly respond to the Complaint. 7. This Motion is not being made for improper delay or for any other improper purpose; rather this Motion is being made in an effort to file an informed response to said Complaint. Wherefore, the Defendants ask for an enlargement of time to serve their Response to the Complaint. DESIGNATION OF EMAIL ADDRESS(ES) FOR SERVICE (Pursuant to Rule 2.516 Fla. R. Jud. Admin.) The undersigned attorneys of The Ticktin Law Group, P.A., hereby designate the following Email Address(es) for service in the above styled matter. Service shall be complete upon emailing to the following email address(es) in this Designation, provided that the provisions of Rule 2.516 are followed. Serv548@LegalBrains.com SERVICE IS TO BE MADE TO EACH AND EVERY EMAIL ADDRESS LISTED IN THIS DESIGNATION AND TO NO OTHERS. 2 THE TICKTIN LAW GROUP, P.A. 600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610 TELEPHONE: (954) 570-6757CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been emailed this 24" day of August 2015, to ROBERT L. CHAPMAN, ESQUIRE, rchapman@sbwiegal.com, Sivyer, Barlow & Watson, P.A., Attorneys for the Plaintiff, 401 East Jackson Street, Suite 2225, Tampa, Florida 33602. THE TICKTIN LAW GROUP, P.A. 600 West Hillsboro Boulevard Suite 220 Deerfield Beach, Florida 33441-1610 Telephone: (954) 570-6757 /s/ Anthony J. Badway ANTHONY J. BADWAY Florida Bar No. 115321 Our Matter No.: 15-1012 3 THE TICKTIN LAW GROUP, P.A. 600 WesT HILLSBORO BOULEVARD, SUITE 220, DEERFIELD BEACH, FLORIDA 33441-1610 TELEPHONE: (954) 570-6757