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Motion for Extension


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IN THE COUNTY COURT IN AND FOR

XXXXXXXXXXXX COUNTY, FLORIDA

CASE NO: XXXXXXXXXXXXXXXXXXXX

MIDLAND FUNDING LLC

Plaintiff,

POLLACK AND ROSEN, P.A.

Attorneys,

vs.

XXXXXXXXXXXXXXXX

Defendant

_____________________________/ MOTION FOR EXTENSION

To Whom It May Concern:

Defendant respectfully asks that the court grant an additional 90-day extension to amend answer to amended complaint and seek additional legal counsel.

Defendant further reserves the right to counter sue for FDCPA violations.

Respectfully,

XXXXXXXXXXXX February XX, 2012

**************

How does this look? After finding these people to be rude and deceptive, I want to fight back now.

There's a lot wrong with what they do and how they do it.

Should I include the bit about the FDCPA or not? I just thought it might make them think twice about what they're doing.

And I really do need time to research this.

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Don't put to whom it may concern. This is a motion, not a letter.

How about something along the lines of

Comes now the Defendant, you, and his/her motion for a continuance.

Then state facts like.

Suit was served XXX

Answer was due XXX

Amended answer is due XXX

Defendant respectfully asks for an additional 90 days (that's a bit much) as Defendant is in the process of attempting to secure counsel to answer this suit and explore possible counterclaims against the Plaintiff.

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So how many days? 30? 60? 70? I need 70!

And I already was denied a motion for their lack of amending answer within 30 days (they took all of 45 days, I answered within a week). I poked holes in their affidavit photocopy which could be for anything, and their generic cc statements.

I so want them to voluntary dismiss so bad!

Thanks Coltsfan!

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Ok, I changed the wording to this: how is it?

Defendant

_____________________________/ MOTION FOR CONTINUANCE

Comes now the Defendant, XXXXXXXXXXX, and his motion for continuance.

Defendant respectfully now moves the court to grant an additional 60-day extension as Defendant is in the process of attempting to secure counsel to answer this suit and explore possible counterclaims against the Plaintiff.

Is this better? Will these clowns back off?

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I went ahead and filed this "motion for continuance" today. It's in the mail in time for late afternoon USPS pickup...

And Pollack and Rosen (or rather one of their tag team phone bullies) called me today about this with words like "about your summons" "against you" and "settle out of court". Not so fast there. Not so easy. This is usurious, vulture, heartless activity and I intend to fight it.

I don't even bother with certified mail anymore. They are not even worth the postage.

The judge mailed me her denial of my motion non-certified, so why not?

I get the feeling that as much as I absolutely hate giving these rude people any money, I may have to settle for a difficult 50% unless the judge hands this poor boy a sandwich.

And it may be I get the short end of the proverbial stick, because I made a joke (I was nervous and was trying to warm up) I actually said in a courtroom "it's my first time. Please be gentle." And it got laughs. But then I opened my stupid mouth again and said "this reminds me of a speech class i took in community college," (I didn't mean anything by it, was just trying to gear up for the 'debate') But then the judge said "only difference is I can put you in jail for contempt." (!)

*to which I promptly stfu of course*

if they are going to screw with me, might as well have some fun lol

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