IN THE COUNTY COURT

BROWARD COUNTY, FLORIDA

CASE NO.: COSO-21-002657

REAL ESTATE SERVICES AND

MANAGEMENT, INC.,

Plaintiff,

v.

TANIECE BRADFORD, and

All others in possession,

Defendant.

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MOTION TO DETERMINE RENT

Pursuant to Florida Statute 83.232, Defendant hereby requires the Court to determine the
amount of rent to be deposited in the registry of the court.

1. On or about March 22, 2021, Plaintiff by and through retained counsel filed a
Complaint for possession and damages related to tenancy of the real property located at 519 NW
23rd Avenue, Fort Lauderdale, FL 33311.
2. Plaintiff alleges that the Defendant “failed to pay the full rental installment of
$1650.00”.
3. The three day notice attached to Plaintiff’s Complaint claims that $1800.00 was the
total amount that the Defendant was indebted to Plaintiff, as of March 15, 2021.
4. Plaintiff did not make any claim for late fees or other charges that would be
considered rent under the contract.
5. Plaintiff’s Complaint fails to provide any accounting for its claim to a total of $1800.
6. Based on Plaintiff’s failure to provide an adequate accounting the Defendant is unable
to ascertain the valid amount of rent alleged to be due.
 CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was delivered to Law
Offices of Dane Stanish, P.A., Plaintiff’s attorney, 3475 Sheridan Street, Suite 209, Hollywood,
FL 33021, at stanishd@gmail.com or via the e-portal service.

Dated: March 30, 2021.

TAYSON C. GAINES, ESQ.

THE GAINES FIRM
Attorney for Defendant
1914 37th St.
West Palm Beach, FL 33407
Telephone (786) 494-0188
Facsimile: (305) 357-4098
Email: admin@tgaineslaw.com
By: /s/ TAYSON C. GAINES
Florida Bar No: 1002329