On July 31, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
Ralph Berthold,
and
Deutsche Bank National Trust Company,
for OTHER RP ACTIONS > $50K, < $250K
in the District Court of Palm Beach County.
Preview
Filing # 112362166 E-Filed 08/25/2020 04:04:07 PM
IN THE CIRCUIT COURT OF THE 157!
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
CIVIL DIVISION
RALPH BERTHOLD,
Plaintiff, Case No. 50-2020-CA-008057-XXXX-MB
vs. DIVISION: AO
DEUTSCHE BANK NATIONAL TRUST
COMPANY, SOLELY AS TRUSTEE FOR
HARBORVIEW MORTGAGE LOAN
TRUST MORTGAGE LOAN PASS-
THROUGH CERTIFICATES, SERIES 2006-
14 AND ANY AND ALL PERSONS
KNOWN OR UNKNOWN CLAIMING AN
INTEREST,
Defendant.
/
DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO
PLAINTIFF'S QUIET TITLE ACTION (COMPLAINT)
Defendant, DEUTSCHE BANK NATIONAL TRUST COMPANY, SOLELY AS
TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE LOAN PASS-
THROUGH CERTIFICATES, SERIES 2006-14 (“Defendant”), by and through undersigned
counsel, hereby moves for an extension of time to respond to the Plaintiff's Complaint and states:
1. Undersigned counsel has recently been retained to represent Defendant in this
matter.
2. Based upon the undersigned's schedule and other business obligations, Defendant
requires an extension of time to properly respond to Plaintiffs’ Complaint.
3. Accordingly, Defendant requests that this Court grant an extension to respond to
the Complaint.
1033952\306486478.v1
CHEN. DAIAARCACUAAIINTY Cl CHADAND ANFY FILED NaINzINnNAN AA-NA-N7 DAA
PILL. PAL BLAU VUUINE TT, PL, OHI. DUUN, ULLIAN, vureuizucy UtUt.ur iveCase No. 50-2020-CA-008057-XXXX-MB
WHEREFORE, Defendant, DEUTSCHE BANK NATIONAL TRUST COMPANY,
SOLELY AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE
LOAN PASS-THROUGH CERTIFICATES, SERIES 2006-14, respectfully requests this Court
grant its motion for an extension of time to respond to the Plaintiff's Complaint and such other
relief as the Court deems just and proper.
CERTIFICATE OF SERVICE
ICERTIFY that on August 25, 2020, the foregoing document is being filed and served via
Florida Courts eFiling Portal and sent via U.S. Mail upon the following:
Ralph Berthold
10648 Old Hammock Way
Wellington, FL 33414
Tel: 561-427-9019
Pro se
HINSHAW & CULBERTSON LLP
s/Miguel A, Gonzalez
Barbara Fernandez
Florida Bar No. 0493767
Miguel A. Gonzalez
Florida Bar No. 58689
2525 Ponce dé Leon Bivd.
Fourth Floor
Coral Gables, FL 33134
Telephone: 305-358-7747
Facsimile: 305-577-1063
Primary: bfernandez@hinshawlaw.com
mgonzalez@hinshawlaw.com
Cannan dawn dannnalle/Dhinchavlavr anes
SeCoNGary: GCORIG uy CGuiisnawiaw.com
Attorneys for Defendant DEUTSCHE BANK
NATIONAL TRUST COMPANY, SOLELY
AS TRUSTEE FOR HARBORVIEW
MORTGAGE LOAN TRUST MORTGAGE
LOAN PASS-THROUGH CERTIFICATES,
SERIES 2006-14 AND ANY AND ALL
PERSONS KNOWN OR UNKNOWN
CLAIMING AN INTEREST
1033952\306486478.v1
Document Filed Date
December 13, 2023
Case Filing Date
July 31, 2020
Category
OTHER RP ACTIONS > $50K, < $250K
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 112362166 E-Filed 08/25/2020 04:04:07 PM IN THE CIRCUIT COURT OF THE 157! JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION RALPH BERTHOLD, Plaintiff, Case No. 50-2020-CA-008057-XXXX-MB vs. DIVISION: AO DEUTSCHE BANK NATIONAL TRUST COMPANY, SOLELY AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE LOAN PASS- THROUGH CERTIFICATES, SERIES 2006- 14 AND ANY AND ALL PERSONS KNOWN OR UNKNOWN CLAIMING AN INTEREST, Defendant. / DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF'S QUIET TITLE ACTION (COMPLAINT) Defendant, DEUTSCHE BANK NATIONAL TRUST COMPANY, SOLELY AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE LOAN PASS- THROUGH CERTIFICATES, SERIES 2006-14 (“Defendant”), by and through undersigned counsel, hereby moves for an extension of time to respond to the Plaintiff's Complaint and states: 1. Undersigned counsel has recently been retained to represent Defendant in this matter. 2. Based upon the undersigned's schedule and other business obligations, Defendant requires an extension of time to properly respond to Plaintiffs’ Complaint. 3. Accordingly, Defendant requests that this Court grant an extension to respond to the Complaint. 1033952\306486478.v1 CHEN. DAIAARCACUAAIINTY Cl CHADAND ANFY FILED NaINzINnNAN AA-NA-N7 DAA PILL. PAL BLAU VUUINE TT, PL, OHI. DUUN, ULLIAN, vureuizucy UtUt.ur iveCase No. 50-2020-CA-008057-XXXX-MB WHEREFORE, Defendant, DEUTSCHE BANK NATIONAL TRUST COMPANY, SOLELY AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE LOAN PASS-THROUGH CERTIFICATES, SERIES 2006-14, respectfully requests this Court grant its motion for an extension of time to respond to the Plaintiff's Complaint and such other relief as the Court deems just and proper. CERTIFICATE OF SERVICE ICERTIFY that on August 25, 2020, the foregoing document is being filed and served via Florida Courts eFiling Portal and sent via U.S. Mail upon the following: Ralph Berthold 10648 Old Hammock Way Wellington, FL 33414 Tel: 561-427-9019 Pro se HINSHAW & CULBERTSON LLP s/Miguel A, Gonzalez Barbara Fernandez Florida Bar No. 0493767 Miguel A. Gonzalez Florida Bar No. 58689 2525 Ponce dé Leon Bivd. Fourth Floor Coral Gables, FL 33134 Telephone: 305-358-7747 Facsimile: 305-577-1063 Primary: bfernandez@hinshawlaw.com mgonzalez@hinshawlaw.com Cannan dawn dannnalle/Dhinchavlavr anes SeCoNGary: GCORIG uy CGuiisnawiaw.com Attorneys for Defendant DEUTSCHE BANK NATIONAL TRUST COMPANY, SOLELY AS TRUSTEE FOR HARBORVIEW MORTGAGE LOAN TRUST MORTGAGE LOAN PASS-THROUGH CERTIFICATES, SERIES 2006-14 AND ANY AND ALL PERSONS KNOWN OR UNKNOWN CLAIMING AN INTEREST 1033952\306486478.v1