IN THE COUNTY COURT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

XXXXX CONDOMINIUM B ASSOCIATION, INC., CIVIL DIVISION CASE NO: 11XXXXX3 CC1

a Florida not-for-profit corporation, Plaintiff, vs.
GLORIA XXXXX ,

and all others in possession of the premises located in Miami Dade County, XXXXXXX Street, #231, Defendant. / DEFENDANT’S EMERGENCY MOTION TO SET ASIDE DEFAULT, FINAL JUDGMENT, AND WRIT OF POSSESSION Come now Defendant, Gloria XXXXXX, by and through her undersigned counsel, and files this Emergency Motion to Set Aside Default, Final Judgment, and Writ of Possession, and states as follows: 1. On September 27, 2011, Plaintiff filed a Complaint in this cause, and a Summons

was issued by mail also on this date. 2. On or about October 5th, the undersigned counsel contacted Plaintiff’s attorney

requesting an extension of time to respond to the complaint. (See attached marked as Exhibit #1). 3. Plaintiff’s attorney refused our request for extension of time, and on or about

October 6th, Defendant filed a Motion to Dismiss Complaint or for the Court to Determine Rent. 4. Subsequently, a Default was entered on October 7th, a Final Judgment was entered

on October 20th, and a Writ of Possession was issued on October 24th, all done without undersigned counsel receiving proper notice. (See attached as Exhibit #2). 5. Opposing counsel was well aware that undersigned counsel represented the

Defendant. There were numerous contacts in the form of telephonic conversations and emails

This motion is filed in good faith and not to unduly delay these proceedings. Final Judgment. Suite 446 Doral. and for further relief as this court deems just and appropriate. Ft. Lauderdale. Defendant’s Motion to Dismiss Complaint or for the Court to Determine Rent has not been heard. on this 1st day of November. Esq.. 2011. Esq. the Defendant request an order granting her Emergency Motion to Set Aside Default. __________________________ .exchanged between both law firms. Libby Calejo Attorney for the Defendant 3900 NW 79th Ave. FL 33354. (See attached marked as Exhibit #3). WHEREFORE. Respectfully submitted. XXXXXXX Street. FL 33166 By: ____________________________ Libby Calejo. 6. and Writ of Possession entered against her in this cause. Additionally. Suite 0. 7. Florida Bar No: 722731 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing motion was sent by facsimile and mailed to: XXXXXXXX..

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