Request,Application: B & Z ASSET MANAGEMENT CORP VS CAMBRIDGE, RONAE D

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                                Filing # 27693057 E-Filed 05/26/2015 02:20:22 PM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

B&Z ASSET MANAGEMENT CORP.
AS SERVICER O/B/O FRANCES RODRIGUEZ
MAGILL; JEROMY TRASORRAS ET AL.,

Plaintiff, CASE NO.: 14-27400CA09
v.

RONAE D. CAMBRIDGE ET AL.,

Defendants,
/

DEFENDANT’S REQUEST FOR ADMISSIONS
NOW COMES, Defendant, Ronae Cambridge, by and through undersigned

counsel, hereby files Defendants’ first set of Request for Admission pursuant to Rule
1.370 of Florida Rules of Civil Procedure and all applicable Rules of Florida Rules of
Civil Procedure.
1. Plaintiff's claims are barred because Plaintiff is not the real party in interest and is
not the proper party to this cause of action.
Answer:
2. Plaintiff's claims are barred because Plaintiff has no interest in the subject note or
mortgage and therefore does not have standing to bring the instant action.
Answer:
3. Plaintiffs claims are barred because Plaintiff has no equitable interest in the
subject note or mortgage and therefore does not have standing to bring the instant action
Answer:
4 Plaintiff's claims are time barred because Plaintiff cause of action expired five (5)

years after the default and/or maturity of the note and mortgage.

Page 1 of 3Answer:

5 Plaintiffs claims are barred because Plaintiff is not in possession of the original
note.

Answer:
6. Plaintiff did not comply with the provisions of the Fair Debt Collection Practices

Act in relation to the instant action and continued to communicate with the
Defendants/mortgagees even though they were represented by counsel

Answer:
7. Plaintiff did not send Defendant(s) a notice of default and intent to accelerate the
subject note and mortgage.

Answer:
8 Plaintiff or Plaintiffs assignor did not provide Defendant with any Truth in
Lending disclosures three days prior to the time when he/she signed the loan documents.

Answer:

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing with mailed to the Plaintiff's

 

attorney, jcooper@polenbergcooper.com; Iquimuyog@polenbergcooper.com;
Iquimuyog@polenbergcooper.com; ydaneshfarpolenbergcooper.com;

jrucker@miamidade.gov. Polenberg Cooper, PLLC, 1351 Sawgrass Corporate Parkway Suite

101, Ft Lauderdale, FL 33323 on this 26" day of May 2015.

Brown & Belleh, P.L.L.C.
Attorney for Defendant
Causeway Square

1801 NE 123" Street Suite 409
North Miami, Florida 33181

Page 2 of 3Tel/Fax: 888-450-7999
Eservice: owei@bellehlaw.com

By: /s/ Owei Z. Belleh

Owei Belleh
FBN.: 617598

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