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  • Dmitry Gorbatov Plaintiff vs. Viciedo Inc Defendant Other document preview
						
                                

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Filing # 35763059 E-Filed 12/21/2015 11:43:41 AM A39709 IN THE CIRCUIT COURT FOR THE ! 17TH JUDICIAL CIRCUIT IN AND FOR : BROWARD COUNTY, FLORIDA DMITRY GORBATOV ! : GENERAL JURISDICTION DIVISION Plaintiff, | : CASE NO. 15-21364 CACE (03) MOTION FOR EXTENSION OF TIME Bar # 217001 vs. VICIEDO, INC. Defendant, \ COME NOW the Defendant, VICIEDO, INC., by and through their undersigned attorneys, and move this Honorable Court for an extension of time to respond to the order To Show Cause, by filing a Counterclaim to Foreclose Lien and would state as grounds: | 1, That counsel has only tecently been retained and has not had sufficient time to review the pleadings, consult with the Defendant, discuss the options that might be available to them as well as any defenses that might be available. 2. This motion is made in good faith and not for the purpose of delay. WHEREFORE, Defendants request that this Court grant Defendant an extension of time to respond to the Order To Show Cause. DATED: December 21, 2015 ! ROBERT M. ABRAMSON, P.L. i Attorneys for Defendant 25 S.E. 2nd Avenue, Suite 1045 Miami, Florida 33131 Telephone: (305) 374-8197 Facsimile: (305) — Primary e-mail: rdbertabramson@yahoo.com. S¢condary e-mail: \garry@gjapa-law.com ae | Bk AY” H ' ROBERT M. AviRON ‘CERTIFICATE OF SERVICE I hereby certify that the ieee was sent this 21st day of December, 2015, to Randall L. Gilbert, Gilbert & Caddy P.A. - Attprney For Plaintiff, at: R uidies eee -com \ BY: \/ LA OF COUNSE! *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 12/21/2015 11:43:41 AM.****