IN THE CIRCUIT COUT FOR THE
SEVENTEENTH JUDICIAL CIRCUIT IN
AND FOR BROWARD COUNTY,
FLORIDA
CASE NO: CACE -21-021315 Division 3
BEHAR, GUTT, & GLAZER, PA.,
a Florida professional association,
Plaintiff,
v.
JOSEPH MABE and
MERRILEE ZAWADZKI
Defendant(s)
__________________________________________
MOTION TO CHANGE VENUE
Now Comes the Defendants, JOSEPH MABE and MERRILEE ZAWADZKI, and request that this Court enter an Order changing the venue from Broward County to the Port Saint Lucie County, Florida or Palm Beach County, Florida, and as grounds thereof states:
- Pursuant to Fla. Stat. §47.011, “[a]ctions shall be brought only in the county where the defendant resides, where the cause of action accrued, or where the property in litigation is located. This section shall not apply to actions against nonresidents.”(Emphasis added).
- The Villa Bankruptcy case involved the Villas of Windmill Point II Property Owners Association, Inc., which is located in Port St Lucie County, Florida, and was litigated before the U.S. Bankruptcy Court for the Southern District of Florida, West Palm Beach Division. Besides, one defendant lives in Port St Lucie County and both the properties owned by the Defendants herein are in Port St. Lucie County.
- For the foregoing reasons, this matter should have been filed in Port Saint Lucie County, Florida or Palm Beach County, Florida.
WHEREFORE, these premises considered, Defendants move this court to enter an order transferring the entire court file in Broward County to either the Port Saint Lucie County, Florida or Palm Beach County, Florida.
Dated: ____________
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via the indicated method on this ______ day of January, 2022 on the following parties:
Via Florida E-portal
BEHAR, GUTT & GLAZER, P.A.
IRA GUTT, ESQ.
STACEY L. GLADDING, ESQ.
DCOTA A-350
1855 GRIFFIN ROAD
FORT LAUDERDALE, FL 33004
E-mail: collections@bgglaw.com
/s/Merrilee Zawadzki
/s/Joseph Mabe
At Legal writing experts, we would be happy to assist in preparing any legal document you need. We are international lawyers and attorneys with significant experience in legal drafting, Commercial-Corporate practice and consulting. In the last few years, we have successfully undertaken similar assignments for clients from different jurisdictions. If given this opportunity, we will be able to prepare the legal document within the shortest time possible.