Filing# 234899091 E-Filed 10/31/2025 02:04:46 PM
`IN THE COUNTY COURT OF THE 17TH
`JUDICIAL COUNTY IN AND FOR
`BROWARD COUNTY, FLORIDA
`A&D MORTGAGE, LLC, a Florida
`Corporation, CASE NO.: CACE 24-008829 (12)
`Plaintiff,
`V.
`REGAL GROUP INT'L, LLC,
`Defendant.
`i
`PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO COMPLY WITH
`DISCOVERY DEADLINE NUNC PRO TUNC
`COMES NOW, the Plaintiff,A&D MORTGAGE, LLC (A&D), by and throughits
`undersignedcounsel, and files this Motion for Extension of Time to Comply with Discovery
`Deadline Nunc Pro Tune states as follows:
`1. On September2,2025, the Court entered an Order resettingthe trial of this ease on
`its January12,2026, docket,with calendar call reset to December 15,2025, and adjustingall pre-
`trialdeadlines to the new date.
`2. On October 26, 2025, the Court entered an Agreed Order regardingA&D
`Mortgage,LLC's, Motion for Final Summary Judgment againstDefendant Regal Group Int'1,
`LLC. This Order greatlynarrowed the few remainingissues for trial. A copy is attached hereto
`as Exhibit "A"
`3. However, due to the time that was requiredto negotiatethe terms of the Agreed
`Order, it was not entered until after the deadline for the initiation of final discoverywhich was
`October 13,2025.
`4. Plaintiff now requiresadditional time to file and serve discoveryon the remaining
`issues that were not resolved by the recent Agreed Order GrantingIn Part Plaintiff's Motion for
`The Law O#ices ofChristopherM. Trapani,P.A.
`215 North Federal Highway, Suite 108, Dania Beach, FL 33004 Telephone (954)530-6957
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2025 02:04:46 PM.****
`
`
`
`
`
`
`
`
`Final Summary Judgment in favor ofA&D.
`5. These issues will be addressed by depositiondiscoveryof the corporate
`representativeofthe Defendant, Regal,and one third party deposition.
`6. Based on the foregoing,Plaintiffrespectfullyrequests that the Court grant a 30-day
`enlargementof time,nunc pro tune, from October 13,2025, until November 12, 2025, to initiate
`discoveryand until December 12,2025, to completediscoveryin this case.
`7. This motion was filed in good faith and not for purposes of undue delay.
`WHEREFORE, Plaintiff,A&D MORTGAGE, LLC, prays that this Court enter an Order
`grantingthis Motion, and for such other relief as the Court deems justand proper.
`f]ERTIFICATE OF CONFERRAL
`I certifythat priorto filingthis motion, I,discussed the relief requestedin this motion by
`email on October 29,2025, with opposingcounsel in an effort to resolve the matter without court
`action,and he has no objectionto the reliefrequestedherein.
`1
`--
`ChrittbpherM. Trapani,Es#
`Florida Bar No.: 865737
`CERTIFICATE OF SERVICE
`St
`I HEREBY CERTIFY on this 8/
`J'
`day of October,2024,lhatatrueandcorrectcopy
`ofthe foregoinghas been served usingthe Florida Courts E-FilingPortal System on all counsel of
`record via transmission of Notice of Electronic Filingby the ePortal System.
`CHRISTOPHER M. TRAPANI, P.A.
`215 North Federal Highway, Suite 108
`Dania Beach, FL 33004
`Tel: (954)530-6957
`Email: emailservice@trapani-law.com
`Chrisidpherm?.Trapani.Esg. J
`Florida Bar No.: 865737
`S:\CI,IENIS\DDW - A&D MORTGAGE\REGAL GROUP\PLEADTNGS & PAPERS\Motion for Extension to Comply With Discovery Cut-Off.docx
`2
`The Law OFtces ofChristopherM. Trapani,P.A.
`215 North Federal Highway, Suite 108, Dania Beach, FL 33004 Telephone (954) 530-6957
`
`
`
`
`
`
`
`
`IXIIIBIT "?
`,,
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`
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`
`
`Filing# 234465616 E-Filed 10/26/2025 09:00:09 PM
`IN THE COUNTY COURT OF THE 17TH
`JUDICIAL COUNTY IN AND FOR
`BROWARD COUNTY, FLORIDA
`A&D MORTGAGE, LLC,
`CASE NO.: CACE 24-008829 (12)
`Plaintiff.
`V.
`REGAL GROUP INT'L, LLC,
`Defendant.
`AGREED ORDER REGARDING PLAINTIFF. A&D MORTGAGE. LLC'S.
`MOTION FOR FINAL SUMMARY JUDGMENT AGAINST
`DEFENDANT, REGAL GROUP INT'L. LLC
`THIS CAUSE came before the Court upon Plaintiff,A&D MORTGAGE, LLC's ("A&D
`Mortgage"),Motion For Final Summary Judgment Against Defendant,REGAL GROUP INT'L, LLC
`("Regal7 on Plaintiffs Second Amended Complaint,which Motion was filed in the record on August
`29, 2025, and the Court having reviewed the Motion, alongwith plaintiffsAmended Statement of
`Material Facts in support thereof filed in the record on April 2, 2025, Ptaint(fsSupplemental
`Declaration Under Penaltyof Perjwy of A&D Mortgage LLC, Representative,filed in the record on
`August 29, 2025, Dejkndant'sResponse in Opposition to Ptainti#'sMotion for Final Summary
`Judgment filed in the record on October 8, 2025, and Defendant'sDeclaration in Oppositionto
`/Plaintgw Summao Judgment,filed in the record on October 8,2025, and the Court havingreviewed
`the other record evidence. having been advised the partiesare in agreement as to the dispositionof
`Plaintiffs pending Motion, and upon otherwise being fullyadvised,
`THE COURT HEREBY FINDS AS FOLLOWS:
`1. On June 3, 2025, this Court entered an Agreed Order Grantingl-Plaintiff'sjAmended Motion
`for Partial Summary JudgmentAs To LiabilityAgainstDefendant,Regal Group Int'l,LLC.
`2. Plaintiff,A&D Mortgage's,presentMotion for Final Summary Judgmentnow asks this Court
`Page 1 of 3
`
`
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`
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`
`
`Case Number CACE24008829
`to enter a final summary judgment awardingdamages againstthe Defendant,Regal Group, and A&D
`Mortgagepresentedthe Court with a SupplementalDeclaration and other record evidence in support of
`itsdamages claim.
`3. Defendant, Regal Group, timely filed with the Court an Opposing Memorandum and an
`OpposingDeclaration which giverise to a genuinedisputeof material facts regardingsome, but not
`all,of the categoriesand amounts of A&D Mortgage'sclaim for damages and regardingthe total
`amount of damages recoverable by A&D Mortgage.
`4. Therefore,a Final Summary Judgment in favor of the Plaintiff and againstthe Defendant is
`not appropriateat this time.
`5. Regal has not challengedthe followingcategoriesand amounts of damages claimed due by
`A&D Mortgage,nor the followingcategory and amount of set off claimed due to Regal:
`PrincipalBalance (Loan # 1044508) $1,059,727.75
`NSF Fee Payment
`$40.00
`Other Fee Payment
`$434.23
`PropertyTaxes Paid by A&D Mortgage,LLC $45,762.20
`Insurance Paid by A&D Mortgage,LLC for 2024-2025 $5,727.29
`Insurance Paid by A&D Mortgage,LLC for 2025-2026 $6,450.87
`Refund of Broker Commission $31,800.00
`PrepaymentPenalty $35,498.60,
`Setoff to Regal Group for Escrow Funds on Deposit ($42,757.26)
`Pursuant to Rule 1.510(e)(2),and Rule 1.510(g),Florida Rules of Civil Procedure,this Court
`considers such categoriesand amounts of damages and setoff not genuinelyin dispute,and the Court
`shall treat them as established facts in this case, absent evidence of an incorrect calculation presentedto
`the Court .
`6. Based upon the Parties' filingsand the record,the Court finds a genuinedisputeas to material
`facts exists as to the amounts due for the followingcategoriesof damages claimed by A&D Mortgage,
`the amount of credit due to Regal for setoff,and the total amount of damages awardable to A&D
`Mortgage,if any:
`Page 2 of 3
`
`
`
`
`
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`
`
`Case Number: CACE24008829
`Note Interest on Loan # 1044508
`1.
`2.
`Default Interest on Loan # 1044508
`2. Late Charge Payments
`LegalFee Payments for foreclosure proceedings:A&D Mortgage.LLC v.
`Maria Del Pilar Vargas,et. al.,2024-011486-CA-0],Miami-Dade County
`3. Circuit Court
`4.
`Setoff to Regal Group for Value of SubjectLoan (Loan # 1044508)
`Total Damages Due from Defendant, RegalGroup, to Plaintiff,A&D
`5. Mortgage,if any
`IT IS THEREUPON ORDERED AND ADJUDGED AS FOLLOWS:
`7. Plaintiffs Motion for Finial Summary Judgment is Granted In Part as to the findingsand
`conclusions in Paragraph 5 and is otherwise Denied Without Prejudice.
`8. This Agreed Order is without waiver of Regal'srightto contest the disputedcategoriesand
`amounts of damages claimed by A&D Mortgage, the disputedamount of any setoff entitlement claimed
`by Regal,the reasonableness of any requestedattorney fees recoverable by A&D Mortgage,and the
`Parties' other claims and defenses not expresslyadjudicatedherein or in the Court's priorOrders.
`9. The Court reserves jurisdictionto determine all remainingclaims and defenses.
`DONE AND ORDERED in Chambers at Broward County,Florida on 26th dav of October. 2025.
`CACE24008829 10-26-2025 3:37 PM
`Hon. Keathan Frink
`CIRCUIT COURT JUDGE
`ElectronicallySignedby Keathan Frink
`Copies Furnished To:
`ChristopherM TrapaniEsq, E-mail : cmt@trapani-law.com
`ChristopherM TrapaniEsq, E-mail :
`emailservice@trapani-law.com
`JOHN J. MURPHY, E-mail : jjmurphy1203@gmail.com
`Robert M Chisholm, E-mail :
`rmc@chisholmlaw.com
`Robert M Chisholm, E-mail : mam@chisholmlaw.com
`Robert M Chisholm, E-mail : reception@chisholmlaw.com
`Page 3 of 3
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`
`IN THE COUNTY COURT OF THE 17TH
`JUDICIAL COUNTY IN AND FOR
`BROWARD COUNTY, FLORIDA
`A&D MORTGAGE, LLC, a Florida
`Corporation, CASE NO.: CACE 24-008829 (12)
`Plaintiff,
`V.
`REGAL GROUP INT'L, LLC,
`Defendant.
`i
`PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO COMPLY WITH
`DISCOVERY DEADLINE NUNC PRO TUNC
`COMES NOW, the Plaintiff,A&D MORTGAGE, LLC (A&D), by and throughits
`undersignedcounsel, and files this Motion for Extension of Time to Comply with Discovery
`Deadline Nunc Pro Tune states as follows:
`1. On September2,2025, the Court entered an Order resettingthe trial of this ease on
`its January12,2026, docket,with calendar call reset to December 15,2025, and adjustingall pre-
`trialdeadlines to the new date.
`2. On October 26, 2025, the Court entered an Agreed Order regardingA&D
`Mortgage,LLC's, Motion for Final Summary Judgment againstDefendant Regal Group Int'1,
`LLC. This Order greatlynarrowed the few remainingissues for trial. A copy is attached hereto
`as Exhibit "A"
`3. However, due to the time that was requiredto negotiatethe terms of the Agreed
`Order, it was not entered until after the deadline for the initiation of final discoverywhich was
`October 13,2025.
`4. Plaintiff now requiresadditional time to file and serve discoveryon the remaining
`issues that were not resolved by the recent Agreed Order GrantingIn Part Plaintiff's Motion for
`The Law O#ices ofChristopherM. Trapani,P.A.
`215 North Federal Highway, Suite 108, Dania Beach, FL 33004 Telephone (954)530-6957
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2025 02:04:46 PM.****
`
`
`
`
`
`
`
`
`Final Summary Judgment in favor ofA&D.
`5. These issues will be addressed by depositiondiscoveryof the corporate
`representativeofthe Defendant, Regal,and one third party deposition.
`6. Based on the foregoing,Plaintiffrespectfullyrequests that the Court grant a 30-day
`enlargementof time,nunc pro tune, from October 13,2025, until November 12, 2025, to initiate
`discoveryand until December 12,2025, to completediscoveryin this case.
`7. This motion was filed in good faith and not for purposes of undue delay.
`WHEREFORE, Plaintiff,A&D MORTGAGE, LLC, prays that this Court enter an Order
`grantingthis Motion, and for such other relief as the Court deems justand proper.
`f]ERTIFICATE OF CONFERRAL
`I certifythat priorto filingthis motion, I,discussed the relief requestedin this motion by
`email on October 29,2025, with opposingcounsel in an effort to resolve the matter without court
`action,and he has no objectionto the reliefrequestedherein.
`1
`--
`ChrittbpherM. Trapani,Es#
`Florida Bar No.: 865737
`CERTIFICATE OF SERVICE
`St
`I HEREBY CERTIFY on this 8/
`J'
`day of October,2024,lhatatrueandcorrectcopy
`ofthe foregoinghas been served usingthe Florida Courts E-FilingPortal System on all counsel of
`record via transmission of Notice of Electronic Filingby the ePortal System.
`CHRISTOPHER M. TRAPANI, P.A.
`215 North Federal Highway, Suite 108
`Dania Beach, FL 33004
`Tel: (954)530-6957
`Email: emailservice@trapani-law.com
`Chrisidpherm?.Trapani.Esg. J
`Florida Bar No.: 865737
`S:\CI,IENIS\DDW - A&D MORTGAGE\REGAL GROUP\PLEADTNGS & PAPERS\Motion for Extension to Comply With Discovery Cut-Off.docx
`2
`The Law OFtces ofChristopherM. Trapani,P.A.
`215 North Federal Highway, Suite 108, Dania Beach, FL 33004 Telephone (954) 530-6957
`
`
`
`
`
`
`
`
`IXIIIBIT "?
`,,
`
`
`
`
`
`
`
`
`Filing# 234465616 E-Filed 10/26/2025 09:00:09 PM
`IN THE COUNTY COURT OF THE 17TH
`JUDICIAL COUNTY IN AND FOR
`BROWARD COUNTY, FLORIDA
`A&D MORTGAGE, LLC,
`CASE NO.: CACE 24-008829 (12)
`Plaintiff.
`V.
`REGAL GROUP INT'L, LLC,
`Defendant.
`AGREED ORDER REGARDING PLAINTIFF. A&D MORTGAGE. LLC'S.
`MOTION FOR FINAL SUMMARY JUDGMENT AGAINST
`DEFENDANT, REGAL GROUP INT'L. LLC
`THIS CAUSE came before the Court upon Plaintiff,A&D MORTGAGE, LLC's ("A&D
`Mortgage"),Motion For Final Summary Judgment Against Defendant,REGAL GROUP INT'L, LLC
`("Regal7 on Plaintiffs Second Amended Complaint,which Motion was filed in the record on August
`29, 2025, and the Court having reviewed the Motion, alongwith plaintiffsAmended Statement of
`Material Facts in support thereof filed in the record on April 2, 2025, Ptaint(fsSupplemental
`Declaration Under Penaltyof Perjwy of A&D Mortgage LLC, Representative,filed in the record on
`August 29, 2025, Dejkndant'sResponse in Opposition to Ptainti#'sMotion for Final Summary
`Judgment filed in the record on October 8, 2025, and Defendant'sDeclaration in Oppositionto
`/Plaintgw Summao Judgment,filed in the record on October 8,2025, and the Court havingreviewed
`the other record evidence. having been advised the partiesare in agreement as to the dispositionof
`Plaintiffs pending Motion, and upon otherwise being fullyadvised,
`THE COURT HEREBY FINDS AS FOLLOWS:
`1. On June 3, 2025, this Court entered an Agreed Order Grantingl-Plaintiff'sjAmended Motion
`for Partial Summary JudgmentAs To LiabilityAgainstDefendant,Regal Group Int'l,LLC.
`2. Plaintiff,A&D Mortgage's,presentMotion for Final Summary Judgmentnow asks this Court
`Page 1 of 3
`
`
`
`
`
`
`
`
`Case Number CACE24008829
`to enter a final summary judgment awardingdamages againstthe Defendant,Regal Group, and A&D
`Mortgagepresentedthe Court with a SupplementalDeclaration and other record evidence in support of
`itsdamages claim.
`3. Defendant, Regal Group, timely filed with the Court an Opposing Memorandum and an
`OpposingDeclaration which giverise to a genuinedisputeof material facts regardingsome, but not
`all,of the categoriesand amounts of A&D Mortgage'sclaim for damages and regardingthe total
`amount of damages recoverable by A&D Mortgage.
`4. Therefore,a Final Summary Judgment in favor of the Plaintiff and againstthe Defendant is
`not appropriateat this time.
`5. Regal has not challengedthe followingcategoriesand amounts of damages claimed due by
`A&D Mortgage,nor the followingcategory and amount of set off claimed due to Regal:
`PrincipalBalance (Loan # 1044508) $1,059,727.75
`NSF Fee Payment
`$40.00
`Other Fee Payment
`$434.23
`PropertyTaxes Paid by A&D Mortgage,LLC $45,762.20
`Insurance Paid by A&D Mortgage,LLC for 2024-2025 $5,727.29
`Insurance Paid by A&D Mortgage,LLC for 2025-2026 $6,450.87
`Refund of Broker Commission $31,800.00
`PrepaymentPenalty $35,498.60,
`Setoff to Regal Group for Escrow Funds on Deposit ($42,757.26)
`Pursuant to Rule 1.510(e)(2),and Rule 1.510(g),Florida Rules of Civil Procedure,this Court
`considers such categoriesand amounts of damages and setoff not genuinelyin dispute,and the Court
`shall treat them as established facts in this case, absent evidence of an incorrect calculation presentedto
`the Court .
`6. Based upon the Parties' filingsand the record,the Court finds a genuinedisputeas to material
`facts exists as to the amounts due for the followingcategoriesof damages claimed by A&D Mortgage,
`the amount of credit due to Regal for setoff,and the total amount of damages awardable to A&D
`Mortgage,if any:
`Page 2 of 3
`
`
`
`
`
`
`
`
`Case Number: CACE24008829
`Note Interest on Loan # 1044508
`1.
`2.
`Default Interest on Loan # 1044508
`2. Late Charge Payments
`LegalFee Payments for foreclosure proceedings:A&D Mortgage.LLC v.
`Maria Del Pilar Vargas,et. al.,2024-011486-CA-0],Miami-Dade County
`3. Circuit Court
`4.
`Setoff to Regal Group for Value of SubjectLoan (Loan # 1044508)
`Total Damages Due from Defendant, RegalGroup, to Plaintiff,A&D
`5. Mortgage,if any
`IT IS THEREUPON ORDERED AND ADJUDGED AS FOLLOWS:
`7. Plaintiffs Motion for Finial Summary Judgment is Granted In Part as to the findingsand
`conclusions in Paragraph 5 and is otherwise Denied Without Prejudice.
`8. This Agreed Order is without waiver of Regal'srightto contest the disputedcategoriesand
`amounts of damages claimed by A&D Mortgage, the disputedamount of any setoff entitlement claimed
`by Regal,the reasonableness of any requestedattorney fees recoverable by A&D Mortgage,and the
`Parties' other claims and defenses not expresslyadjudicatedherein or in the Court's priorOrders.
`9. The Court reserves jurisdictionto determine all remainingclaims and defenses.
`DONE AND ORDERED in Chambers at Broward County,Florida on 26th dav of October. 2025.
`CACE24008829 10-26-2025 3:37 PM
`Hon. Keathan Frink
`CIRCUIT COURT JUDGE
`ElectronicallySignedby Keathan Frink
`Copies Furnished To:
`ChristopherM TrapaniEsq, E-mail : cmt@trapani-law.com
`ChristopherM TrapaniEsq, E-mail :
`emailservice@trapani-law.com
`JOHN J. MURPHY, E-mail : jjmurphy1203@gmail.com
`Robert M Chisholm, E-mail :
`rmc@chisholmlaw.com
`Robert M Chisholm, E-mail : mam@chisholmlaw.com
`Robert M Chisholm, E-mail : reception@chisholmlaw.com
`Page 3 of 3
`
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`
`
`
`
`
`
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