On September 23, 2018 a
Motion,Ex Parte
was filed
involving a dispute between
Homebrige Financial Service Inc,
Newrez Llc,
and
Parkey, Mark D,
Parkey, Michael R,
for CIRCUIT CIVIL
in the District Court of Osceola County.
Preview
Filing # 80634445 E-Filed 11/09/2018 04:23:51 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR OSCEOLA COUNTY, FLORIDA
HOMEBRIDGE FINANCIAL
SERVICES, INC.,
Plaintiff,
v. Case No.: 2018-CA-003041-MF
MICHAEL R. PARKEY, et al.,
Defendants.
/
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
COMES NOW, Defendant, MICHAEL R. PARKEY (hereinafter referred to as
“Defendant”), by and through the undersigned Counsel, and pursuant to Fla. R. Civ. P. 1.090(b),
hereby moves this Court for an extension of time to serve a response to Plaintiff's Complaint, and
in support thereof, states as follows:
1. Defendant recently hired the Law Offices of Legendre & Legendre, PLLC to represent him
in this action.
2. The undersigned is in the process of obtaining the documents filed in this case to date so
he can serve the proper response to Plaintiffs Complaint.
3. However, given that the undersigned was recently hired, he needs to obtain the documents
filed in this case to date, and he must conduct a brief investigation into the facts of this case
in order to respond properly to the subject Complaint, the undersigned will need an
additional thirty (30) days to properly respond.
4. Asaresult of the above, Defendant respectfully requests thirty (30) additional days to serve
a Response to Plaintiffs Complaint.
WHEREFORE, Defendant, MICHAEL R. PARKEY, respectfully requests this Court to
enter an Order permitting Defendant to have an additional thirty (30) days to serve a response to
Plaintiff's Complaint.
Page 1 of 2CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that a true and correct copy of the foregoing has been furnished
by E-mail through
E-portal to Attorneys for Plaintiff, of Albertelli Law
(servealaw@albertellilaw.com), P.O. Box 23028, Tampa, Florida 33623, on this 9° day of
November, 2018.
/s/ ANTHONY N. LEGENDRE., II, Esq.
ANTHONY N. LEGENDRE, II, Esq.
Fla. Bar No.: 67221
Primary E-mail: anthonylegendre@live.com
Secondary E-mail: Anthony@Law-Legends.com
Secondary E-mail: Ronald@Law-legends.com
Law Offices of Legendre & Legendre, PLLC
P.O. Box 948599
Maitland, FL 32794-8599
(407) 460-8525
Attorney for Defendant,
MICHAEL R. PARKEY
Page 2 of 2
Document Filed Date
November 09, 2018
Case Filing Date
September 23, 2018
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Filing # 80634445 E-Filed 11/09/2018 04:23:51 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR OSCEOLA COUNTY, FLORIDA HOMEBRIDGE FINANCIAL SERVICES, INC., Plaintiff, v. Case No.: 2018-CA-003041-MF MICHAEL R. PARKEY, et al., Defendants. / MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT COMES NOW, Defendant, MICHAEL R. PARKEY (hereinafter referred to as “Defendant”), by and through the undersigned Counsel, and pursuant to Fla. R. Civ. P. 1.090(b), hereby moves this Court for an extension of time to serve a response to Plaintiff's Complaint, and in support thereof, states as follows: 1. Defendant recently hired the Law Offices of Legendre & Legendre, PLLC to represent him in this action. 2. The undersigned is in the process of obtaining the documents filed in this case to date so he can serve the proper response to Plaintiffs Complaint. 3. However, given that the undersigned was recently hired, he needs to obtain the documents filed in this case to date, and he must conduct a brief investigation into the facts of this case in order to respond properly to the subject Complaint, the undersigned will need an additional thirty (30) days to properly respond. 4. Asaresult of the above, Defendant respectfully requests thirty (30) additional days to serve a Response to Plaintiffs Complaint. WHEREFORE, Defendant, MICHAEL R. PARKEY, respectfully requests this Court to enter an Order permitting Defendant to have an additional thirty (30) days to serve a response to Plaintiff's Complaint. Page 1 of 2CERTIFICATE OF SERVICE I HEREBY CERTIFY, that a true and correct copy of the foregoing has been furnished by E-mail through E-portal to Attorneys for Plaintiff, of Albertelli Law (servealaw@albertellilaw.com), P.O. Box 23028, Tampa, Florida 33623, on this 9° day of November, 2018. /s/ ANTHONY N. LEGENDRE., II, Esq. ANTHONY N. LEGENDRE, II, Esq. Fla. Bar No.: 67221 Primary E-mail: anthonylegendre@live.com Secondary E-mail: Anthony@Law-Legends.com Secondary E-mail: Ronald@Law-legends.com Law Offices of Legendre & Legendre, PLLC P.O. Box 948599 Maitland, FL 32794-8599 (407) 460-8525 Attorney for Defendant, MICHAEL R. PARKEY Page 2 of 2