On August 31, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Us Bank National Association,
Us Bank National Association Lasalle National Association Sbm,
and
Antonio G Martin Esq,
Antonio G Martin Esq Of The Derrick Drive Land Trust 6826 Dated 08 01 2017 Trst,
Any And All Unknown Parties,
Mortgage Electronic Registration Systems Inc,
Mortgage Electronic Registration Systems Inc Ownit Mortgage Solutions Inc Nom,
Orange County Fl,
Rafael Agosto,
Rafael Agosto Rafael O Agosto Aka,
The Independent Savings Plan Company,
The Independent Savings Plan Company Ispc Dba,
Unknown Successor Trustee Of The Derrick Drive Land Trust 6826 Dated August 1 2017,
Us Bank National Association,
Us Bank National Association The Cbass Mortgage Loan Asset Backed Certificate Series 2007 Sl1 Trst,
Wanda I Agosto,
Wanda I Agosto Wanda Agosto Aka,
for 3
in the District Court of Orange County.
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Filing # 67913837 E-Filed 02/13/2018 03:49:51 PM
IN THE CIRCUIT COURT OF THE
NINTH JUDICIAL CIRCUIT IN
AND FOR ORANGE COUNTY, FLORIDA
CASE NO.: 2017-CA-008145-O
US BANK NATIONAL ASSOCIATION, AS
SUCCESSOR TRUSTEE, TO BANK OF
AMERICA, NATIONAL ASSOCIATION,
SUCCESSOR BY MERGER TO LASALLE
NATIONAL ASSOCIATION, AS TRUSTEE
FOR OWNIT MORTGAGE LOAN TRUST,
MORTGAGE LOAN ASSET-BACKED
CERTIFICATES, SERIES 2006-7,
Plaintiff,
v.
RAFAEL AGOSTO A/K/A RAFAEL O.
AGOSTO; WANDA I. RODRIGUEZ A/K/A
WANDA AGOSTO, et al.,
Defendants,
_______________________________________/
DEFENDANT, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.
AS NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC.’S
MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendant, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC. (“Defendant”), by and through its
undersigned counsel, files this Motion for Extension of Time within which to file a response to
Plaintiff’s Complaint, and states as follows:
1. Plaintiff commenced the instant foreclosure action naming Defendant as a party
pursuant to its alleged interest in a mortgage.
2. The undersigned counsel requires an extension of time to respond to Plaintiff’s
Complaint for the purposes of conferring with his client to further investigate the allegations
contained in the Complaint.
140383.04648/106627620v.1
3. The purpose of this extension is not to delay but to provide additional time to
investigate the issues and respond appropriately.
4. The requested extension will not prejudice any party.
WHEREFORE, Defendant, MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC., respectfully
requests an extension of time to respond to Plaintiff’s Complaint.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically
filed this 13th day of February, 2018, with the Clerk of the Circuit Court using the Florida Courts
E-Filing Portal and served via an automatic email generated by the Florida Courts E-Filing Portal
to: Jonathan Meisels, Esq. and Olivia Soden, Esq., Robertson, Anschutz & Schneid, P.L., 6409
Congress Avenue, Suite 100, Boca Raton, FL 33487 (mail@rasflaw.com); Michael D. Ginsberg,
Esq., Attorney for Defendant ISPC, 1115 Gunn Hwy, Suite 100, Odessa, FL 33556 (fc-
ispc@theispc.com); Wanda Agosto-Rodriguez, 6826 Derrick Drive, Orlando, FL 32818; Wanda
Agosto-Rodriguez, 1980 Garwood Drive, Orlando, FL 32822; Rafael Agosto, 6826 Derrick
Drive, Orlando, FL 32818; Rafael Agosto, 1980 Garwood Drive, Orlando, FL 32822.
BLANK ROME LLP
500 E. Broward Blvd., Suite 2100
Ft. Lauderdale, FL 33394
Telephone: 954-512-1800
Facsimile: 954-512-1818
/s/ Daniel S. Hurtes
DANIEL S. HURTES
Florida Bar No. 69104
DHurtes@BlankRome.com
BRFLeservice@BlankRome.com
NICOLE R. TOPPER
Florida Bar No. 558591
NTopper@BlankRome.com
140383.04648/106627620v.1
Preview
Filing # 67913837 E-Filed 02/13/2018 03:49:51 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 2017-CA-008145-O US BANK NATIONAL ASSOCIATION, AS SUCCESSOR TRUSTEE, TO BANK OF AMERICA, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO LASALLE NATIONAL ASSOCIATION, AS TRUSTEE FOR OWNIT MORTGAGE LOAN TRUST, MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2006-7, Plaintiff, v. RAFAEL AGOSTO A/K/A RAFAEL O. AGOSTO; WANDA I. RODRIGUEZ A/K/A WANDA AGOSTO, et al., Defendants, _______________________________________/ DEFENDANT, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC.’S MOTION FOR EXTENSION OF TIME TO RESPOND TO PLAINTIFF’S COMPLAINT Defendant, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC. (“Defendant”), by and through its undersigned counsel, files this Motion for Extension of Time within which to file a response to Plaintiff’s Complaint, and states as follows: 1. Plaintiff commenced the instant foreclosure action naming Defendant as a party pursuant to its alleged interest in a mortgage. 2. The undersigned counsel requires an extension of time to respond to Plaintiff’s Complaint for the purposes of conferring with his client to further investigate the allegations contained in the Complaint. 140383.04648/106627620v.1 3. The purpose of this extension is not to delay but to provide additional time to investigate the issues and respond appropriately. 4. The requested extension will not prejudice any party. WHEREFORE, Defendant, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC., respectfully requests an extension of time to respond to Plaintiff’s Complaint. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was electronically filed this 13th day of February, 2018, with the Clerk of the Circuit Court using the Florida Courts E-Filing Portal and served via an automatic email generated by the Florida Courts E-Filing Portal to: Jonathan Meisels, Esq. and Olivia Soden, Esq., Robertson, Anschutz & Schneid, P.L., 6409 Congress Avenue, Suite 100, Boca Raton, FL 33487 (mail@rasflaw.com); Michael D. Ginsberg, Esq., Attorney for Defendant ISPC, 1115 Gunn Hwy, Suite 100, Odessa, FL 33556 (fc- ispc@theispc.com); Wanda Agosto-Rodriguez, 6826 Derrick Drive, Orlando, FL 32818; Wanda Agosto-Rodriguez, 1980 Garwood Drive, Orlando, FL 32822; Rafael Agosto, 6826 Derrick Drive, Orlando, FL 32818; Rafael Agosto, 1980 Garwood Drive, Orlando, FL 32822. BLANK ROME LLP 500 E. Broward Blvd., Suite 2100 Ft. Lauderdale, FL 33394 Telephone: 954-512-1800 Facsimile: 954-512-1818 /s/ Daniel S. Hurtes DANIEL S. HURTES Florida Bar No. 69104 DHurtes@BlankRome.com BRFLeservice@BlankRome.com NICOLE R. TOPPER Florida Bar No. 558591 NTopper@BlankRome.com 140383.04648/106627620v.1