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Motion for Extension of Time

IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA

WACHOVIA MORTGAGE
CORPORATION CASE NUMBER: 10-0xxxx CACE (25)
Plaintiff,
vs.
B.L. et. al.,
Defendants.
__________________________________/

DEFENDANT’S MOTION FOR EXTENSION OF TIME TO SERVE RESPONSE TO COMPLAINT

The Defendant, B.L., by and through undersigned counsel, files this Motion for Extension of Time to Serve Response to Complaint and as grounds therefore states:

1. This is a mortgage foreclosure action.

2. B.L. was served with the complaint on or about February 10, 2010.

3. Responses to the complaint are due to be served March 2, 2010.

4. The undersigned is currently being retained and will need addition. 

5. The undersigned has not had the opportunity to review the complaint and the attachments to determine what defenses, if any, exist. 

6. The undersigned respectfully requests an additional twenty-days in which to serve/file an answer or pre-answer motion to the complaint. 

WHEREFORE, Defendant, B.L., respectfully request that this court enter an order granting this Motion for Extension of Time to Serve Response to Complaint.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on this February 25, 2010, a true and correct copy of the foregoing was faxed (X) and mailed (X) to: William A. Malone, Esq., Florida Default Law Group, P.L., 9119 Corporate Lake Dr. Ste. 300, Tampa, FL 33634.

Attorney for Defendant
2100 East Hallandale Beach Blvd. Ste 200
Hallandale Beach, FL 33009
Telephone: (954) 455-0800
Facsimile: (954) 455-9649

By_______________________________________
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997

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This is a sample document related to a specific set of facts and circumstances and should not be used or relied upon if any foreclosure, deficiency judgment, short sale or any other real estate matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.