On February 10, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Bank Of America Na,
and
Carrington At Coconut Creek Condo Assn Inc,
Delvecchio, Margarita,
Delvecchio, Nicholas A,
for Real Prop Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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*#** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/28/2013 4:48:23 PM.*#**
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUpbgetranically Filed 05/28/2013 04:48:25 PM ET
IN AND FOR BROWARD COUNTY, FLORIDA.
BANK OF AMERICA, NLA. SUCT
MERGER TO BAC HOME LOANS SERVICING,
LP, PKA COUNTRY WIDE HOME LOANS,
SERVICING. LP Case No. CACE 12003696
SSOR BY
Plaintiff. Division: i
vs.
NICHOLAS A. DELVECCHIO, MARGARITA
DELVECCHIO A/K/A MARGUARITA
DEL ‘CHIO, et al.
Defendant(s).
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME
TO RESPOND TO DEFENDANT'S INTERROGATORIES
‘The Plaintiff, BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS
SERVICING, LP, FKA COUNTRYWIDE HOME LOANS SERVICING, LP (“Plaintiff), by and through its
undersigned attomey, pursuant toRule 1.090(b) Florida Rules of Civil Procedure, files its Motion for Enlargement of
Time to respond to Defendant, NICHOLAS A. DELVECCHIO (“Defendant”) Defendant's Interrogatories ("Discovery
Requests") and states as fotlows;
L This is a mortgage foreclosure action brought by the Plaintiff relating to real property Jocated in
Broward County, Florida
2. On May 3, 2013, Plaintiff was served by U.S, mail with the Defendant's Discovery Requests.
3. The undersigned is awaiting documents from the Plaintiff in order to properly prepare and file its
responses and objections to the Discovery Requests.
4. The undersigned is in need of additional time in order to review the necessary documentation from his
client in order to properly prepare its responses and objections to the Discovery Requests.
5. The undersigned is hereby requesting additional time to file its respons
s and objections to the
Discovery Requests.
6. The Defendant will not be prejudiced in any manner by the Plaintiff being granted an enlargement of
time,
WHEREFORE, the Plaintiff, requests this Honorable Court grant it an extension of time to file its response to
the Discovery Requests.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true copy of the foregoing has been furnished by U.S. mail or Email to:
NICHOLAS A. DELVECCHIO, 4820 N STATE ROAD 7 APT 104, CORAL SPRINGS, FL 33073; MARGARITA
DELVECCHIO A/K/A MARGUARITA DELVECCHIO, 4820 N STATE ROAD 7 APT 104, CORAL SPRINGS, FL
33073: this QP day of .2013
‘Ann. Saint-Hubert / Florida Bar #0070067
SSaint-Hubert@kasslaw.com
Kass Shuler, P.A., Attorneys for Plaintiff
P.O. Box 800, 1505 N, Florida Ave.
Tampa, FL 33601
(813) 229-0900
Sta
The Primary e-mail address for electronic service
of all pleadings in this case under Rule 2.516 is as
follows:ForeclosureService@kasslaw.com
1122433/emm
Document Filed Date
May 28, 2013
Case Filing Date
February 10, 2012
Category
Real Prop Homestead Res Fore - >$50K - <$250,000
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*#** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/28/2013 4:48:23 PM.*#** IN THE CIRCUIT COURT OF THE SEVENTEENTH JUpbgetranically Filed 05/28/2013 04:48:25 PM ET IN AND FOR BROWARD COUNTY, FLORIDA. BANK OF AMERICA, NLA. SUCT MERGER TO BAC HOME LOANS SERVICING, LP, PKA COUNTRY WIDE HOME LOANS, SERVICING. LP Case No. CACE 12003696 SSOR BY Plaintiff. Division: i vs. NICHOLAS A. DELVECCHIO, MARGARITA DELVECCHIO A/K/A MARGUARITA DEL ‘CHIO, et al. Defendant(s). PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S INTERROGATORIES ‘The Plaintiff, BANK OF AMERICA, N.A., SUCCESSOR BY MERGER TO BAC HOME LOANS SERVICING, LP, FKA COUNTRYWIDE HOME LOANS SERVICING, LP (“Plaintiff), by and through its undersigned attomey, pursuant toRule 1.090(b) Florida Rules of Civil Procedure, files its Motion for Enlargement of Time to respond to Defendant, NICHOLAS A. DELVECCHIO (“Defendant”) Defendant's Interrogatories ("Discovery Requests") and states as fotlows; L This is a mortgage foreclosure action brought by the Plaintiff relating to real property Jocated in Broward County, Florida 2. On May 3, 2013, Plaintiff was served by U.S, mail with the Defendant's Discovery Requests. 3. The undersigned is awaiting documents from the Plaintiff in order to properly prepare and file its responses and objections to the Discovery Requests. 4. The undersigned is in need of additional time in order to review the necessary documentation from his client in order to properly prepare its responses and objections to the Discovery Requests. 5. The undersigned is hereby requesting additional time to file its respons s and objections to the Discovery Requests. 6. The Defendant will not be prejudiced in any manner by the Plaintiff being granted an enlargement of time, WHEREFORE, the Plaintiff, requests this Honorable Court grant it an extension of time to file its response to the Discovery Requests. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true copy of the foregoing has been furnished by U.S. mail or Email to: NICHOLAS A. DELVECCHIO, 4820 N STATE ROAD 7 APT 104, CORAL SPRINGS, FL 33073; MARGARITA DELVECCHIO A/K/A MARGUARITA DELVECCHIO, 4820 N STATE ROAD 7 APT 104, CORAL SPRINGS, FL 33073: this QP day of .2013 ‘Ann. Saint-Hubert / Florida Bar #0070067 SSaint-Hubert@kasslaw.com Kass Shuler, P.A., Attorneys for Plaintiff P.O. Box 800, 1505 N, Florida Ave. Tampa, FL 33601 (813) 229-0900 Sta The Primary e-mail address for electronic service of all pleadings in this case under Rule 2.516 is as follows:ForeclosureService@kasslaw.com 1122433/emm