On December 08, 2015 a
Motion,Ex Parte
was filed
involving a dispute between
International Village Association Inc,
and
Doe, Jane,
Doe, John,
Nicolas, Rene,
Rene Nicolas, Unknown Spouse Of,
for CC Equity > $5,000 - $15,000
in the District Court of Broward County.
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Filing # 36127679 E-Filed 01/04/2016 05:16:08 PM
IN THE COUNTY COURT OF THE
17TH JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA
INTERNATIONAL VILLAGE
ASSOCIATION, INC., a Florida
not-for-profit corporation
Plaintiff,
CASE NO. 15-009587 (70)
vs. CONO
RENE NICOLAS; UNKNOWN SPOUSE
OF RENE NICOLAS; if living, and if dead,
the unknown heirs, devisees, grantees,
assignees, lienors, creditors, trustees,
and all other parties claiming an interest
by, through, under, or against RENE
NICOLAS, UNKNOWN SPOUSE
OF RENE NICOLAS; JOHN DOE and
JANE DOE as unknown tenants in
possession
Defendants,,
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW, the Defendant, RENE NICOLAS, by and through the undersigned
counsel, and hereby files this, its Motion for Extension of Time to Respond to Plaintiffs
Complaint, and in support thereof states as follows:
1. The Defendant, RENE NICOLAS contacted the undersigned and authorized the
undersigned to communicate with Plaintiff's attorney, in an effort to resolve this matter.
2. To date, the undersigned has not received a response to said written communication.
3. The undersigned has not had an opportunity to review the substance of the complaint
with the Defendant and needs additional time to respond to the complaint.
** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/4/2016 5:16:08 PM.****4. This case is less than one (1) month old such that a reasonable extension will not
unduly prejudice the parties or the Court.
WHEREFORE, the Defendant, RENE NICOLAS, requests that this Motion be granted
together with such other relief as this Court deems just and proper.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-mailed to
Elaine M. Gatsos, Esq., 1499 West Palmetto Park Road, Suite 210, Boca Raton, Florida 33486,
this 4'" day of January, 2016, |:-Mail:emgatsos@aol.com.
DONALD S. GOLDRICH, P.A.
Attorney for Defendant
P. O. Box 970735
Coconut Creek, Florida 33097
(954) 428-2960
E-Mail:dsgoldrichlawfirm@ gmail.com
By:s/ Donald S. Goldrich
DONALD S. GOLDRICH
Florida Bar No. 103683
Document Filed Date
January 04, 2016
Case Filing Date
December 08, 2015
Category
CC Equity > $5,000 - $15,000
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Filing # 36127679 E-Filed 01/04/2016 05:16:08 PM IN THE COUNTY COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA INTERNATIONAL VILLAGE ASSOCIATION, INC., a Florida not-for-profit corporation Plaintiff, CASE NO. 15-009587 (70) vs. CONO RENE NICOLAS; UNKNOWN SPOUSE OF RENE NICOLAS; if living, and if dead, the unknown heirs, devisees, grantees, assignees, lienors, creditors, trustees, and all other parties claiming an interest by, through, under, or against RENE NICOLAS, UNKNOWN SPOUSE OF RENE NICOLAS; JOHN DOE and JANE DOE as unknown tenants in possession Defendants,, DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW, the Defendant, RENE NICOLAS, by and through the undersigned counsel, and hereby files this, its Motion for Extension of Time to Respond to Plaintiffs Complaint, and in support thereof states as follows: 1. The Defendant, RENE NICOLAS contacted the undersigned and authorized the undersigned to communicate with Plaintiff's attorney, in an effort to resolve this matter. 2. To date, the undersigned has not received a response to said written communication. 3. The undersigned has not had an opportunity to review the substance of the complaint with the Defendant and needs additional time to respond to the complaint. ** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/4/2016 5:16:08 PM.****4. This case is less than one (1) month old such that a reasonable extension will not unduly prejudice the parties or the Court. WHEREFORE, the Defendant, RENE NICOLAS, requests that this Motion be granted together with such other relief as this Court deems just and proper. I HEREBY CERTIFY that a true and correct copy of the foregoing has been e-mailed to Elaine M. Gatsos, Esq., 1499 West Palmetto Park Road, Suite 210, Boca Raton, Florida 33486, this 4'" day of January, 2016, |:-Mail:emgatsos@aol.com. DONALD S. GOLDRICH, P.A. Attorney for Defendant P. O. Box 970735 Coconut Creek, Florida 33097 (954) 428-2960 E-Mail:dsgoldrichlawfirm@ gmail.com By:s/ Donald S. Goldrich DONALD S. GOLDRICH Florida Bar No. 103683