On December 31, 2019 a
Order to Show Cause
was filed
involving a dispute between
Bank Of America Na,
and
Mooney, Melissa L,
for CONTRACTS AND INDEBTEDNESS - COUNTY
in the District Court of Pinellas County.
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Filing # 118261388 E-Filed 12/15/2020 04:47:31 PM
IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY, FLORIDA
CASE NO.: 20-000019-CO
BANK OF AMERICA, N.A.,
Plaintiff
VS.
MELISSA L MOONEY,
Defendant(s).
i
RESPONSE TO ORDER FOR SHOWING OF GOOD CAUSE
COMES NOW the Plaintiffby and through its undersigned counsel and files this its Showing of
Good Cause as to why this case should not be dismissed for lack ofprosecutionand in support thereof
states as follows:
1. Plaintiff filed its lawsuit and has a summons issued.
2. Plaintiff's summons was returned as non-served. The Defendant was unable
to be located and or had moved from their last known address.
3. Subsequently, Plaintiff skip traced the account and locatedthe Defendant at a new
address.
4. Plaintiff wishes to have an opportunity to serve the Defendant at the new address
by having an alias summons issued.
WHEREFORE, Plaintiff respectfully request that this Honorable Court not dismiss this matter for
lack of prosecution.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via regular
U.S. Mail to Defendant, MELISSA L MOONEY, at 60 AVON DR, SAFETY HARBOR FL 34695-2048.
Dated: 12-15-2020 Respectfully submitted,
,
20-
UANDREU, PALMA, LAVIN& SOLIS, PLLC
815 NW 57th Avenue, Suite 401
Miami, FL 33126
Tel: (877) 229-5972
Fax: (800) 391-2178
Document service e-mail:
eservice @andreupalma.com
1918494
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT
A DEBT, AND ANY INFORMATIONOBTAINED WILL BE USED FOR THAT PURPOSE.
***ELECTRONICALLYFILED 12/15/2020 04:47:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Document Filed Date
December 15, 2020
Case Filing Date
December 31, 2019
Category
CONTRACTS AND INDEBTEDNESS - COUNTY
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Filing # 118261388 E-Filed 12/15/2020 04:47:31 PM IN THE COUNTY COURT IN AND FOR PINELLAS COUNTY, FLORIDA CASE NO.: 20-000019-CO BANK OF AMERICA, N.A., Plaintiff VS. MELISSA L MOONEY, Defendant(s). i RESPONSE TO ORDER FOR SHOWING OF GOOD CAUSE COMES NOW the Plaintiffby and through its undersigned counsel and files this its Showing of Good Cause as to why this case should not be dismissed for lack ofprosecutionand in support thereof states as follows: 1. Plaintiff filed its lawsuit and has a summons issued. 2. Plaintiff's summons was returned as non-served. The Defendant was unable to be located and or had moved from their last known address. 3. Subsequently, Plaintiff skip traced the account and locatedthe Defendant at a new address. 4. Plaintiff wishes to have an opportunity to serve the Defendant at the new address by having an alias summons issued. WHEREFORE, Plaintiff respectfully request that this Honorable Court not dismiss this matter for lack of prosecution. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via regular U.S. Mail to Defendant, MELISSA L MOONEY, at 60 AVON DR, SAFETY HARBOR FL 34695-2048. Dated: 12-15-2020 Respectfully submitted, , 20- UANDREU, PALMA, LAVIN& SOLIS, PLLC 815 NW 57th Avenue, Suite 401 Miami, FL 33126 Tel: (877) 229-5972 Fax: (800) 391-2178 Document service e-mail: eservice @andreupalma.com 1918494 THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATIONOBTAINED WILL BE USED FOR THAT PURPOSE. ***ELECTRONICALLYFILED 12/15/2020 04:47:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***