On December 19, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
Bayview Loan Servicing Llc,
Jpmorgan Chase Bank Nat Assn,
and
Galt Ocean Club Condo Assn Inc,
Hill York Service Corp,
Kipta, Susan M,
Pro Star Pool Supplies Inc,
for Real Prop Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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Electronically Filed 09/04/2013 11:27:38 AM ET
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
MORGAN CHASE BANK, NATIONAL
SSOCIATION
AM
Plaintiff, Case No.: CACE12035025
Division: WW
JUSAN M. KIPTA, et al.
9/4/2913.4 1:27:37
Defendant(s).
i
PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME
(OQ RESPOND TO DEFENDANT'S REQUEST FOR PRODUCTION, INTERROGATORIES AND REQUEST FOR ADMISSIONS
The Plaintiff, SPMORGAN CHASE BANK, NATIONAL ASSOCIATION (“Plaintiff”), by and through its undersigned attorney, pursuant
t&Rule 1,090(b) Florida Rules of Civil Procedure, files its Motion for Enlargement of Time to respond to Defendant, SUSAN M. KIPTA
‘ORMANSCLE!
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: JONATHAN KLINE ESQ.
Jonathan Kline P.A., emailservice@jklawfl.com, Jonathan.kline@jklawfl.com, Attorney for Defendant, SUSAN M. KIPTA; K JOY
MATTINGLY, Bical ae diet nieee eee Attomey for Defendant, GALT OCEAN CLUB CONDOMINIUM.
etendent”) Defendant's Request for Production, Interrogatories and Request for Admissions ("Discovery Requests") and states as follows:
2 lL This is a mortgage foreclosure action brought by the Plaintiff relating to real property located in Broward County, Florida.
x 2. On August 22, 2013, Plaintiff was served with the Defendant's Discovery Requests, which was received August 22, 2013.
EB 3. The undersigned is awaiting documents from the Plaintiff in order to properly prepare and file its responses and objections to
the Discovery Requests.
z 4. The undersigned is in need of additional time in order to review the necessary documentation from his client in order to properly
epare its responses and objections to the Discovery Requests,
8 5. The undersigned is hereby requesting additional time to file its responses 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.
2
2
oo
a
Q
d
ia
ASSOCIATION, INC.: this day of August, 2013
NRoefgr6@kasslaw.com
Kass Shufer, P_A., Attorneys for Plaintiff
P.O. Box 800, 1505 N. Florida Ave.
Tampa, FL 33601
(813) 229-0900
The Primary e-mail address for electronic service of all pleadings in
this case under Rule 2.516 is as follows:
ForeclosureService@kasslaw.com
320406/1 116284/pkm
ATTA A (OCEAN AC
CULATION
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION ys. SUSAN. “RIPTA, etal. 320400/1116284/pkm
Broward COUNTY
Pet 1
Document Filed Date
September 04, 2013
Case Filing Date
December 19, 2012
Category
Real Prop Homestead Res Fore - >$50K - <$250,000
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Electronically Filed 09/04/2013 11:27:38 AM ET IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MORGAN CHASE BANK, NATIONAL SSOCIATION AM Plaintiff, Case No.: CACE12035025 Division: WW JUSAN M. KIPTA, et al. 9/4/2913.4 1:27:37 Defendant(s). i PLAINTIFF’S MOTION FOR ENLARGEMENT OF TIME (OQ RESPOND TO DEFENDANT'S REQUEST FOR PRODUCTION, INTERROGATORIES AND REQUEST FOR ADMISSIONS The Plaintiff, SPMORGAN CHASE BANK, NATIONAL ASSOCIATION (“Plaintiff”), by and through its undersigned attorney, pursuant t&Rule 1,090(b) Florida Rules of Civil Procedure, files its Motion for Enlargement of Time to respond to Defendant, SUSAN M. KIPTA ‘ORMANSCLE! 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: JONATHAN KLINE ESQ. Jonathan Kline P.A., emailservice@jklawfl.com, Jonathan.kline@jklawfl.com, Attorney for Defendant, SUSAN M. KIPTA; K JOY MATTINGLY, Bical ae diet nieee eee Attomey for Defendant, GALT OCEAN CLUB CONDOMINIUM. etendent”) Defendant's Request for Production, Interrogatories and Request for Admissions ("Discovery Requests") and states as follows: 2 lL This is a mortgage foreclosure action brought by the Plaintiff relating to real property located in Broward County, Florida. x 2. On August 22, 2013, Plaintiff was served with the Defendant's Discovery Requests, which was received August 22, 2013. EB 3. The undersigned is awaiting documents from the Plaintiff in order to properly prepare and file its responses and objections to the Discovery Requests. z 4. The undersigned is in need of additional time in order to review the necessary documentation from his client in order to properly epare its responses and objections to the Discovery Requests, 8 5. The undersigned is hereby requesting additional time to file its responses 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. 2 2 oo a Q d ia ASSOCIATION, INC.: this day of August, 2013 NRoefgr6@kasslaw.com Kass Shufer, P_A., Attorneys for Plaintiff P.O. Box 800, 1505 N. Florida Ave. Tampa, FL 33601 (813) 229-0900 The Primary e-mail address for electronic service of all pleadings in this case under Rule 2.516 is as follows: ForeclosureService@kasslaw.com 320406/1 116284/pkm ATTA A (OCEAN AC CULATION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION ys. SUSAN. “RIPTA, etal. 320400/1116284/pkm Broward COUNTY Pet 1