Motion,Ex Parte: FREEDOM MORTGAGE CORPORATION Plaintiff vs. ANDRE ST STEVE KIFFIN Defendant

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                                Filing # 114373109 E-Filed 10/02/2020 05:28:57 PM


                  IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
                             IN AND FOR BROWARD COUNTY, FLORIDA


        FREEDOM        MORTGAGE       CORPORATION                       CASE NO.: CACE 19-021666


                        Plaintiff,

        VS.




        ANDRE ST STEVE KIFFIN

                        Defendant.




                           MOTION TO WITHDRAW AS COUNSEL OF RECORD



                  MATOS LEGAL, PLLC (“MATOS LEGAL”), by and through the undersigned counsel,

        hereby files its Ex-Parte Motion to Withdraw as Counsel of Record for the Defendant, ANDRE ST

         STEVE KIFFIN (“ANDRE KIFFIN”), and as grounds states as follows:

                  1     That MATOS LEGAL was retained to represent the Defendant, ANDRE KIFFIN,

        in the above-referenced matter.

                  2.    That irreconcilable differences have arisen between MATOS LEGAL and ANDRE

        KIFFIN.

                  3     That MATOS LEGAL requests that the firm be relieved of responsibility as counsel

        of record in this matter and that all future pleadings and correspondence be directed to the

        Defendant at 2126 N 32™ Ave., Hollywood, FL 33021.




              #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN,          CLERK 10/02/2020 05:28:56 PM.****
WHEFEFORE, MATOS LEGAL, requests this Honorable Court enter an Order granting

Motion to Withdraw as Counsel of Record and directing all future pleadings and correspondence be

forwarded directly to Defendant at 2126 N 32™ Ave., Hollywood, FL 33021.



                                            RESPECTFULLY SUBMITTED,

                                            /s/ Rosalind J. Matos, Esquire
                                            ROSALIND J. MATOS, ESQUIRE
                                            MATOS LEGAL, PLLC
                                            Attomey for Defendant
                                            2645 Executive Park Drive, Suite 676
                                            Weston, FL 33331
                                            rosalind@matoslegal.com
                                            Telephone: (954) 531-5658
                                            Florida Bar No.: 474967


                                CERTIFICATE OF SERVICE



       I HEREBY CERTIFY that a true and correct copy of the foregoing was filed with the
Clerk of the Court via E-Filing Portal and served via ePortal E-Mail to: Jonathan Meisels, Esq.
Robertson, Anschutz & Schneid, P.L., 6409 Congress Avenue, Suite 100, Boca Raton, FL 33487,
mail@rasflaw.com, on this 2™ day of October 2020.



                                            /s/ Rosalind J. Matos, Esquire
                                            ROSALIND J. MATOS, ESQUIRE
                                            Florida Bar No.: 474967




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