On November 09, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Jpmorgan Chase Bank Na,
and
Dorsey, Timothy J,
Sunrise The City Of,
for Real Prop Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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Filing # 29849314 E-Filed 07/20/2015 02:22:34 PM
IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
JP MORGAN CHASE BANK,
NATIONAL ASSOCIATION,
Plaintiff,
VS. CASE NO: 12-31667 CACE 11
CIVIL DIVISION
TIMOTHY J. DORSEY, et. al.,
Defendants.
a
MOVANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO
PLAINTIFF’S COMPLAINT
COMES NOW, Movant, TIMOTHY J. DORSEY, by and through undersigned
counsel, and without waiving Movant’s objection to the propriety of service herein and
without waving proper service upon him and without submitting himself to the
jurisdiction of the court, files this Motion for Enlargement of Time to Respond to
Plaintiff's Summons and Verified Mortgage Foreclosure Complaint filed in this action
and files this Motion for Enlargement of Time to Respond to Plaintiff's Complaint filed
in this action and in support thereof says as follows:
1. The Plaintiff herein filed its Complaint upon the Movant herein TIMOTHY J.
DORSEY.
2. Due to catastrophic computer issues, counsel for Movant has been unable to
complete a response to Plaintiff's Summons Complaint and requires additional time to
file a response to Plaintiff's Summons and Complaint.
Motion for Enlargement of Time — JP MORGAN CHASE BANK v. DORSEY, et al.
Page | of 2
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/20/2015 2:22:34 PM.****3. This Motion is not filed for the purpose of harassment or delay, and the other
parties herein will in no way be prejudiced by the granting of the subject motion.
WHEREFORE, Movant TIMOTHY J. DORSEY without waiving Movant’s
objection to the propriety of service herein and without waving proper service upon him
move for an enlargement of time in which to respond to the Plaintiffs Complaint.
Respectfully submitted,
/S/ MARGERY E. GOLANT
Golant & Golant, P.A.,
Attorneys for Movant TIMOTHY J. DORSEY
By: Margery E. Golant, Esquire
2385 NW Executive Center Drive, Suite 100
Boca Raton, FL 33431
Tel. (561) 206-6171 Fax (561) 206-6172
Florida Bar No. 44466
CERTIFICATE OF SERVICE
I HEREBY Certify that a copy of this document was served via Email to the
persons listed below on July 20, 2015.
Ashland Roberts, Esq.
Phelan Hallinan PLC
2727 West Cypress Creek Road
Fort Lauderdale, FL 33309
Facsimile: (954) 462-7001
E-Mail: FL. Service@phelanhallinan.com
/S/ MARGERY E. GOLANT
Margery E. Golant, Esq.
o Margery E. Golant, Esquire
Oo Stuart M. Golant, Esquire
o Richard R. Widell, Esquire
Motion for Enlargement of Time — JP MORGAN CHASE BANK v. DORSEY, et al.
Page 2 of 2
Document Filed Date
July 20, 2015
Case Filing Date
November 09, 2012
Category
Real Prop Homestead Res Fore - >$50K - <$250,000
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Filing # 29849314 E-Filed 07/20/2015 02:22:34 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff, VS. CASE NO: 12-31667 CACE 11 CIVIL DIVISION TIMOTHY J. DORSEY, et. al., Defendants. a MOVANT’S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW, Movant, TIMOTHY J. DORSEY, by and through undersigned counsel, and without waiving Movant’s objection to the propriety of service herein and without waving proper service upon him and without submitting himself to the jurisdiction of the court, files this Motion for Enlargement of Time to Respond to Plaintiff's Summons and Verified Mortgage Foreclosure Complaint filed in this action and files this Motion for Enlargement of Time to Respond to Plaintiff's Complaint filed in this action and in support thereof says as follows: 1. The Plaintiff herein filed its Complaint upon the Movant herein TIMOTHY J. DORSEY. 2. Due to catastrophic computer issues, counsel for Movant has been unable to complete a response to Plaintiff's Summons Complaint and requires additional time to file a response to Plaintiff's Summons and Complaint. Motion for Enlargement of Time — JP MORGAN CHASE BANK v. DORSEY, et al. Page | of 2 *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/20/2015 2:22:34 PM.****3. This Motion is not filed for the purpose of harassment or delay, and the other parties herein will in no way be prejudiced by the granting of the subject motion. WHEREFORE, Movant TIMOTHY J. DORSEY without waiving Movant’s objection to the propriety of service herein and without waving proper service upon him move for an enlargement of time in which to respond to the Plaintiffs Complaint. Respectfully submitted, /S/ MARGERY E. GOLANT Golant & Golant, P.A., Attorneys for Movant TIMOTHY J. DORSEY By: Margery E. Golant, Esquire 2385 NW Executive Center Drive, Suite 100 Boca Raton, FL 33431 Tel. (561) 206-6171 Fax (561) 206-6172 Florida Bar No. 44466 CERTIFICATE OF SERVICE I HEREBY Certify that a copy of this document was served via Email to the persons listed below on July 20, 2015. Ashland Roberts, Esq. Phelan Hallinan PLC 2727 West Cypress Creek Road Fort Lauderdale, FL 33309 Facsimile: (954) 462-7001 E-Mail: FL. Service@phelanhallinan.com /S/ MARGERY E. GOLANT Margery E. Golant, Esq. o Margery E. Golant, Esquire Oo Stuart M. Golant, Esquire o Richard R. Widell, Esquire Motion for Enlargement of Time — JP MORGAN CHASE BANK v. DORSEY, et al. Page 2 of 2