On May 10, 152 a
Motion,Ex Parte
was filed
involving a dispute between
U.S. Bank, National Association As Legal Title Trustee For Truman 2016 Sc6 Title Trust,
and
And All Unknown Parties Claiming Interests By, Through, Under Or Against A Named Defendant To This Actiion, Or Having Or Claiming To Have Any Right, Title Or Interest In The Property Herein Described,
Lamatrice, Thomas F.,
Unknown Tenant No.1,
Unknown Tenant No. 2,
for Non-Homestead Residential Foreclosure 50,001 - 250,000
in the District Court of Charlotte County.
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Filing # 53822804 E-Filed 03/16/2017 01:12:59 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
U.S. BANK, NATIONAL ASSOCIATION
Plaintiff,
Case No. 17-CA-100
v.
THOMAS F. LAMATRICE,
Defendants,
/
MOTION FOR EXTENSION TO RESPOND TO COMPLAINT
Defendant, THOMAS F. LAMATRICE, by and through his undersigned counsel and
pursuant to Fla.R.Civ.P. 1.090(b), moves this Court for a 30-day extension of time to respond to
the Complaint, and would show:
1. The undersigned has just recently been retained in this matter.
2. There are numerous attachments to the Complaint which must be thoroughly
reviewed before a substantive response can be prepared. Also, it appears that Defendant may have
a 1.140(b) defense, which would require that the undersigned communicate with him and prepare
necessary affidavits before responding.
3. Under the circumstances, said Defendant should be entitled to a 30-day extension
of time to respond to the Complaint. This time is necessary to ensure that the undersigned can get
through their other work and still have time to prepare the necessary response(s) to the Complaint
(without rushing through them and potentially prejudicing Defendant’s rights).
WHEREFORE Defendant respectfully requests an Order in accordance with the
foregoing.!
' Defendant also places Plaintiff on notice of its failure to post a non-resident cost bond.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via
electronic mail to answers@shdlegalgroup.com, Kelly M. Williams, Esq., SHD Legal Group, P.A.,
on this 16th day of March, 2017.
/s/ Mark P. Stopa
Mark P. Stopa, Esquire
FBN: 550507
STOPA LAW FIRM
2202 N. Westshore Blvd.
Suite 200
Tampa, FL 33607
Telephone: (727) 851-9551
ATTORNEY FOR DEFENDANT
Document Filed Date
March 16, 2017
Case Filing Date
May 10, 152
Category
Non-Homestead Residential Foreclosure 50,001 - 250,000
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Filing # 53822804 E-Filed 03/16/2017 01:12:59 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA U.S. BANK, NATIONAL ASSOCIATION Plaintiff, Case No. 17-CA-100 v. THOMAS F. LAMATRICE, Defendants, / MOTION FOR EXTENSION TO RESPOND TO COMPLAINT Defendant, THOMAS F. LAMATRICE, by and through his undersigned counsel and pursuant to Fla.R.Civ.P. 1.090(b), moves this Court for a 30-day extension of time to respond to the Complaint, and would show: 1. The undersigned has just recently been retained in this matter. 2. There are numerous attachments to the Complaint which must be thoroughly reviewed before a substantive response can be prepared. Also, it appears that Defendant may have a 1.140(b) defense, which would require that the undersigned communicate with him and prepare necessary affidavits before responding. 3. Under the circumstances, said Defendant should be entitled to a 30-day extension of time to respond to the Complaint. This time is necessary to ensure that the undersigned can get through their other work and still have time to prepare the necessary response(s) to the Complaint (without rushing through them and potentially prejudicing Defendant’s rights). WHEREFORE Defendant respectfully requests an Order in accordance with the foregoing.! ' Defendant also places Plaintiff on notice of its failure to post a non-resident cost bond.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via electronic mail to answers@shdlegalgroup.com, Kelly M. Williams, Esq., SHD Legal Group, P.A., on this 16th day of March, 2017. /s/ Mark P. Stopa Mark P. Stopa, Esquire FBN: 550507 STOPA LAW FIRM 2202 N. Westshore Blvd. Suite 200 Tampa, FL 33607 Telephone: (727) 851-9551 ATTORNEY FOR DEFENDANT