IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT, IN AND FOR

MIAMI-DADE COUNTY, FLORIDA

GUARDIAN AD LITEM, ADMINISTRATOR AD LITEM, AND

ATTORNEY AD LITEM’S MOTION TO STAY PROCEEDINGS PURSUANT TO

COMES NOW, the undersigned court-appointed Guardian, Administrator and Attorney

Ad Litem, duly appointed by the Honorable Judge Amy Steele, to attempt to represent the

interests of the Defendant, and respectfully moves this Honorable Court for the entry of

an Order Staying the instant proceeding pursuant to Servicemembers' Civil Relief Act ("SCRA"),

50 U.S.C. app. §§ 501 et seq, and in support thereof states as follows:

1. Undersigned counsel is currently attempting to locate and communicate with the

Defendant, . Counsel has sent communication via the Bureau of Naval

Personnel Locator.

2. At this juncture counsel is awaiting a response, but has been informed that such a

response could be delayed in light of the process via a third party.

3. Section 521 of the SCRA provides that when requested by counsel for a

servicemember defendant, the court will grant a stay of proceedings for no less than ninety (90)

days if it determines that (1) there may be a defense and the defense cannot be presented without

the defendant's presence; or (2) after due diligence the defendant's attorney has not been able to

contact the defendant or otherwise determine if a meritorious defense exists.

3. Undersigned counsel hereby moves for a stay of proceedings pursuant to the

aforementioned. At this juncture, counsel has been unable to contact the defendant, but will

prepare and file a report once a reasonable amount of time has passed by which the Defendant

could have contacted the undersigned.

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 4. Pursuant to Section 521 of the SCRA, this court should grant a stay of

proceedings for no less than ninety (90) days.

5. Undersigned counsel certifies that this Motion is made in good faith and not for

the purpose of unnecessary delay. Counsel will move expeditiously to perform all other duties to

the best of his abilities.

WHEREFORE, undersigned counsel respectfully requests that this Honorable Court

enter an Order Staying the Proceedings, and for any and such other relief as this court deems just

and equitable.

Respectfully submitted,

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed

to

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