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Filing #62707460 E-Filed 10/11/2017 03:42:38 PM
IN THE CIRCUIT COURT OF THE 9TH JUDICIAL
CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
WELLS FARGO BANK, N.A.
Plaintiff,
vs,
DIANA L MOLITOR
Defendant(s),
CASE NO.: 2017-CA-008098-O
PLAINTIFF’S EX PARTE MOTION TO STAY/ABATE LITIGATION
DUE TO HURRICANE IRMA.
COMES NOW, the Plaintiff, WELLS FARGO BANK, N.A., by and through its undersigned
counsel, hereby files its Ex parte Motion to Stay/Abate Litigation due to Hurricane Irma and states:
On August 31, 2017, Plaintiff, WELLS FARGO BANK, N.A.,(Hereinafter “Plaintiff”), filed the
instant lawsuit against Defendant DIANA L MOLITOR seeking monetary damages for a breach of
credit card agreement.
As a result of the impact of Hurricane Irma, the Plaintiff is seeking to abate this action in order to
allow the Defendant additional time to recover from any potential effects of the storm.
Based upon the above, the Plaintiff hereby respectfully requests that the subject action be stayed
for a duration of time up and until December 12, 2017; after which time the Plaintiff be allowed to
move forward with the litigation of this action without further order from this Court.
THIS SPACE INTENTIONALLY LEFT BLANK
WHEREFORE, WELLS FARGO BANK, N.A., respectfully requests that this Court enter an Order
granting Plaintiff's Ex parte Motion to Stay/Abate Litigation up and until December 12, 2017, and grant any
further relief deemed just and proper.
Respectfully Submitted,
NADERPOUR & ASSOCIATES, P.A.
Attorneys for Plaintiff
2743 Hollywood Blvd,
Hollywood, Florida 33020
(954) 926-4233 tel.
(954) 926-4238 fax.
Primary Service Email Address:
servicel @naderpourlaw.com
By
[]AMIR N OUR, ESO., FBN: 70262
[] JODI M. FOX, ESQ., FBN: 24872
{ ] SABERIN J. JAMSHED, ESQ., FBN: 88665
{] BENJAMIN W. BUCK, JR, ESQ., FBN:117639
[WILLIE JAMES BRICE, JR, ESQ., FBN:120226
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by mail to: DIANA
L MOLITOR 2495 TAHOE CIR, WINTER PARK FL 32792-1170 this day of er 2017.
By: A hpi
[ ] AMIR NADERPOUR, ESQ., FBN: 70262
[ ] JODI M. FOX, ESQ., FBN: 24872
[] SABERIN J, JAMSHED, ESQ., FBN: 88665
] BENJAMIN W. BUCK, JR, ESQ., FBN:117639
[WILLIE JAMES BRICE, JR, ESQ., FBN: 120226
Case No.: 2017-CA-008098-O
Internal File No.: 23175/FEMA
Page2
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Filing #62707460 E-Filed 10/11/2017 03:42:38 PM IN THE CIRCUIT COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, vs, DIANA L MOLITOR Defendant(s), CASE NO.: 2017-CA-008098-O PLAINTIFF’S EX PARTE MOTION TO STAY/ABATE LITIGATION DUE TO HURRICANE IRMA. COMES NOW, the Plaintiff, WELLS FARGO BANK, N.A., by and through its undersigned counsel, hereby files its Ex parte Motion to Stay/Abate Litigation due to Hurricane Irma and states: On August 31, 2017, Plaintiff, WELLS FARGO BANK, N.A.,(Hereinafter “Plaintiff”), filed the instant lawsuit against Defendant DIANA L MOLITOR seeking monetary damages for a breach of credit card agreement. As a result of the impact of Hurricane Irma, the Plaintiff is seeking to abate this action in order to allow the Defendant additional time to recover from any potential effects of the storm. Based upon the above, the Plaintiff hereby respectfully requests that the subject action be stayed for a duration of time up and until December 12, 2017; after which time the Plaintiff be allowed to move forward with the litigation of this action without further order from this Court. THIS SPACE INTENTIONALLY LEFT BLANK WHEREFORE, WELLS FARGO BANK, N.A., respectfully requests that this Court enter an Order granting Plaintiff's Ex parte Motion to Stay/Abate Litigation up and until December 12, 2017, and grant any further relief deemed just and proper. Respectfully Submitted, NADERPOUR & ASSOCIATES, P.A. Attorneys for Plaintiff 2743 Hollywood Blvd, Hollywood, Florida 33020 (954) 926-4233 tel. (954) 926-4238 fax. Primary Service Email Address: servicel @naderpourlaw.com By []AMIR N OUR, ESO., FBN: 70262 [] JODI M. FOX, ESQ., FBN: 24872 { ] SABERIN J. JAMSHED, ESQ., FBN: 88665 {] BENJAMIN W. BUCK, JR, ESQ., FBN:117639 [WILLIE JAMES BRICE, JR, ESQ., FBN:120226 CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by mail to: DIANA L MOLITOR 2495 TAHOE CIR, WINTER PARK FL 32792-1170 this day of er 2017. By: A hpi [ ] AMIR NADERPOUR, ESQ., FBN: 70262 [ ] JODI M. FOX, ESQ., FBN: 24872 [] SABERIN J, JAMSHED, ESQ., FBN: 88665 ] BENJAMIN W. BUCK, JR, ESQ., FBN:117639 [WILLIE JAMES BRICE, JR, ESQ., FBN: 120226 Case No.: 2017-CA-008098-O Internal File No.: 23175/FEMA Page2