On October 22, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
American Express National Bank,
and
Oliva, Rene,
for CC Credit Card Debt >$15,000 - $30,000
in the District Court of Broward County.
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Filing # 117100307 E-Filed 11/23/2020 09:38:03 AM
IN THE COUNTY COURT IN AND
FOR BROWARD COUNTY, FLORIDA
AMERICAN EXPRESS NATL BANK, CASE NO.: COSO20010897
Plaintiff,
v.
RENE OLIVA,
Defendant(s).
/
MOTION FOR EXTENSION OF TIME
Defendant, RENE OLIVA, by and through his/her undersigned attorney, moves for an
extension of time to respond to Plaintiff's Complaint:
1. Defendant has been unable to retain counsel until now.
2. Defendant requests additional time to respond to Plaintiff's Complaint.
3. This Motion is not being presented for any improper purpose, such as to harass, cause
unnecessary delay, or needlessly increase the cost of litigation.
WHEREFORE, Defendant prays this court will grant additional time for Defendant to
respond to Plaintiff's Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing instrument was
delivered by email service to Stephanie D. Simmonds, Esq. attorney(s) for Plaintiff at
lawfirmFL@rsieh.com, and any other email addresses listed with the Florida e-filing portal and
on November 23, 2020.
4s Joel D. Lucoff
Joel D. Lucoff
Fla. Bar No. 192163
Debt Shield Law
3440 Hollywood Blvd., Suite 415,
Hollywood, FL 33021
(754) 800-5299
service@debtshieldlawyer.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/23/2020 09:38:02 AM.****
Document Filed Date
November 23, 2020
Case Filing Date
October 22, 2020
Category
CC Credit Card Debt >$15,000 - $30,000
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Filing # 117100307 E-Filed 11/23/2020 09:38:03 AM IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA AMERICAN EXPRESS NATL BANK, CASE NO.: COSO20010897 Plaintiff, v. RENE OLIVA, Defendant(s). / MOTION FOR EXTENSION OF TIME Defendant, RENE OLIVA, by and through his/her undersigned attorney, moves for an extension of time to respond to Plaintiff's Complaint: 1. Defendant has been unable to retain counsel until now. 2. Defendant requests additional time to respond to Plaintiff's Complaint. 3. This Motion is not being presented for any improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation. WHEREFORE, Defendant prays this court will grant additional time for Defendant to respond to Plaintiff's Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing instrument was delivered by email service to Stephanie D. Simmonds, Esq. attorney(s) for Plaintiff at lawfirmFL@rsieh.com, and any other email addresses listed with the Florida e-filing portal and on November 23, 2020. 4s Joel D. Lucoff Joel D. Lucoff Fla. Bar No. 192163 Debt Shield Law 3440 Hollywood Blvd., Suite 415, Hollywood, FL 33021 (754) 800-5299 service@debtshieldlawyer.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/23/2020 09:38:02 AM.****