Motion,Ex Parte: BANK OF NEW YORK MELLON vs. LARGE, VICKIE ALEXANDRA

• 
• 
• 
• 

						
                                
Preview
                                Filing # 117836244 E-Filed 12/08/2020 01:02:16 PM

IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR BAY COUNTY, FLORIDA
CIVIL DIVISION
THE BANK OF NEW YORK MELLON fik/a Case #: 19004414CA.

THE BANK OF NEW YORK as Trustee for
Nationstar Home Equity Loan Trust 2007-A

Plaintiff,
-VS.-

Vickie Alexandra Large a/k/a Victoria
Alexandra Large a/k/a Vickie Large; et al.

Defendant(s).
PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO RESPOND TO

DEFENDANT(S), VICKIE ALEXANDRA LARGE A/K/A VICTORIA ALEXANDRA
LARGE A/K/A VICKIE LARGE, REQUEST FOR PRODUCTION

Plaintiff, THE BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW
YORK as Trustee for Nationstar Home Equity Loan Trust 2007-A, by and through its
undersigned attorney hereby files this Motion for Extension of Time to Respond to Defendant(s),
Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large, Request for
Production and sets forth:

1, This is an action in foreclosure of real property located in Bay County, Florida.

2. On or about December 1, 2020, Defendant(s), Vickie Alexandra Large a/k/a
Victoria Alexandra Large a/k/a Vickie Large, served his/her Request for Production.

3. Plaintiff requires additional time in which to formulate its responses to
Defendant(s) Request for Production.

4. This Motion is made in good faith and not for the purposes of harassment or
delay.

5. Defendant(s), Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a

Vickie Large, will not be prejudiced by the Court granting said Motion.WHEREFORE, Plaintiff requests this Honorable court enter an order granting Plaintiff
an Extension of Time in which to respond to Defendant(s), Vickie Alexandra Large a/k/a
Victoria Alexandra Large a/k/a Vickie Large, Request for Production preserving all objections,
and any other relief the Court deems just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by U.S. Mail and/or email service if an email address is so listed below on this_8 day of

December , 2020 to the following:

Shawn Michael Large, 3426 Douglas Road, Apartment B, Panama City, FL 32405

Vickie Alexandra Large a/k/a Victoria Alexandra Large a/k/a Vickie Large, c/o Mitch Dever,
Esq., mitchdever@comeast.net

*Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiff's counsel
hereby designates its primary email address for the purposes of
email service as: SFGService@logs.com*

SHAPIRO, FISHMAN & GACHE, LLP
Attorneys for Plaintiff

4630 Woodland Corporate Blvd., Suite 100
Tampa, Florida 33614

Telephone: (813) 880-8888 Ext. 55153

Fax: (813) 880-8800

For Email Service Only: SFGService@logs.com
For all other inquiries: jkopf@logs.com

By: /s/ Jennifer Kopf.
Jennifer Kopf, Esq.
FL Bar # 50949

Pursuant to the Fair Debt Collections Practices Act, you are advised that this office may be
deemed a debt collector and any information obtained may be used for that purpose.

19-321900 FCO1 CXE