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Filing # 104685873 E-Filed 03/11/2020 10:07:03 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE-19-026084
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE FOR AMERIQUEST
MORTGAGE SECURITIES INC., ASSET-BACKED
PASS-THROUGH CERTIFICATES, SERIES ARSI
2006-M3,
Plaintiff,
vs.
SUZANNE A. LEVENE A/K/A SUZANNE
LEVENE, et al.
Defendants
/
PLAINTIFF’S MOTION FOR COURT DEFAULT
Plaintiff, WELLS FARGO BANK, N.A., AS TRUSTEE FOR CARRINGTON MORTGAGE,
LOAN TRUST, SERIES 2006-FRE1 ASSET-BACKED PASS-THROUGH CERTIFICATES, by and
through its undersigned counsel, hereby moves this Court for entry of a default by the Court against
Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE, and in support thereof states:
1. On or about December 28, 2019, Plaintiff served Defendant, SUZANNE A, LEVENE A/K/A
SUZANNE LEVENE, with the Foreclosure Complaint.
2. On or about January 22, 2020, Defendant SUZANNE A. LEVENE A/K/A SUZANNE LEVENE
filed a Motion for Enlargement of Time.
3. On or about February 11, 2020, this Court entered an Agreed Order granting Defendant’s Motion
for Enlargement of Time, allowing ten (10) days for Defendant, SUZANNE A. LEVENE A/K/A
SUZANNE LEVENE to file a responsive pleading. A copy of the Agreed Order is attached
hereto as Exhibit “A”. ,
4, Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE has yet to file an Answer or
response to the Plaintiff's Complaint.
5, Plaintiff asks this Court to enter a default against Defendant, SUZANNE A. LEVENE A/K/A
SUZANNE LEVENE pursuant to Fla, R. Civ. P. 1.500(b), which states:
PHH14948-19/ase
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2020 05:04:36 PM.****When a party against whom affirmative relief is sought has failed to plead or
otherwise defend as provided by these rules or any applicable statute or any order of
court, the court may enter a default against such party; provided that if such party
has filed or served any paper in the action, that party shall be served with notice of
the application for default.
WHEREFORE, Plaintiff respectfully requests that this Court grant its Motion for Court Default,
as well as for such further relief this Court deems just and proper.
I HEREBY CERTIFY that a true and correct copy of the foregoing was sent to the parties and
attorneys of record as shown on the attached service list. The service was completed on this iL day of
ter be , 2020. On the service list, if an email address is designated for a party, then
that party was served via email only. If no email address is listed for that defendant on the service list,
then that party was served via regular U.S. Mail.
VAN NESS LAW FIRM, PLC
1239 E. Newport Center Drive, Suite 110
Deerfield Beach, Florida 33442
Ph: (954) 571-2031
PRIMARY EMAIL: Pleadings@vanlawfl.com
Jan D. Jagentorf-Esq.
Bar Number: 33487
CASE NO: CACE-19-026084
SERVICE LIST
ODALYS M, IBRAHUM, ESQ.
IBRAHIM LAW P.A.
11200 PINES BLVD., SUITE 200
PEMBROKE PINES, FL 33026
ATTORNEY FOR SUZANNE A. LEVENE A/K/A SUZANNE LEVENE
Email: pleadings@ibrahimlawpa.com
ELAINE M. GATSOS, ESQ.
LAW OFFICE OF ELAINE M. GATSOS
5541 N. UNIVERSITY DRIVE, SUITE 102
CORAL SPRINGS, FL 33067
ATTORNEY FOR OAKBROOK CONDOMINIUM ASSOCIATION, INC.
Email: emgatsos@aol.com, realestategatsos@aol.com
SYNCHRONY BANK
F/K/A GE MONEY BANK, A CORPORATION
F/K/A GE CAPITAL CONSUMER CARD CO.
140 WEKIVA SPRINGS RD
LONGWOOD, FL 32779
PHH14948-19/asceFiling # 103157475 E-Filed 02/12/2020 02:30:45 AM
Exhibit NAY
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE19026084 DIVISION 11. JUDGE Andrea Gundersen
Deutsche Bank National Trust Company
Plaintiff(s) / Petitioner(s)
Vv.
Suzanne A, Leven, et al
Defendant(s) / Respondent(s)
/
AGREED ORDER ON DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME
THIS CAUSE came on to be heard on Defendant's Motion for Enlargement of Time to file a response to
Complaint and the court being fully advised on the premises and the partied having agreed to the terms
of this order, it is
ORDERED AND ADJUDGED as follows:
41. Defendant shall have ten (10) days from the date of this order to file a responsive pleading
to the complaint filed in this action.
DONE and ORDERED in Chambers, at Broward County, Florida on 02-1 1-2020.
oper giant oa ton o02rM
CACE19026084 02-11-2020 6:02 PM
Hon. Andrea Gundersen
CIRCUIT JUDGE
Electronically Signed by Andrea Gundersen
Copies Furnished To:
Elaine M Gatsos , E-mail : lauraphillipsemg@aol.com
Elaine M Gatsos , E-mail : emgatsos@aol.com
Elaine M Gatsos , E-mail : realestategatsos@aol.com
John Anthony Van Ness , E-mail : E-Filing@vanlawfl.com
Maya Rubinov , E-mail : pleadings@vanlawfl.com
Odalys M. Ibrahim , E-mail : oibrahim@ibrahimlawpa.com
Odalys M. Ibrahim , E-mail : kathy@ibrahimlawpa.com
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Filing # 104685873 E-Filed 03/11/2020 10:07:03 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE-19-026084 DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE FOR AMERIQUEST MORTGAGE SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES, SERIES ARSI 2006-M3, Plaintiff, vs. SUZANNE A. LEVENE A/K/A SUZANNE LEVENE, et al. Defendants / PLAINTIFF’S MOTION FOR COURT DEFAULT Plaintiff, WELLS FARGO BANK, N.A., AS TRUSTEE FOR CARRINGTON MORTGAGE, LOAN TRUST, SERIES 2006-FRE1 ASSET-BACKED PASS-THROUGH CERTIFICATES, by and through its undersigned counsel, hereby moves this Court for entry of a default by the Court against Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE, and in support thereof states: 1. On or about December 28, 2019, Plaintiff served Defendant, SUZANNE A, LEVENE A/K/A SUZANNE LEVENE, with the Foreclosure Complaint. 2. On or about January 22, 2020, Defendant SUZANNE A. LEVENE A/K/A SUZANNE LEVENE filed a Motion for Enlargement of Time. 3. On or about February 11, 2020, this Court entered an Agreed Order granting Defendant’s Motion for Enlargement of Time, allowing ten (10) days for Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE to file a responsive pleading. A copy of the Agreed Order is attached hereto as Exhibit “A”. , 4, Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE has yet to file an Answer or response to the Plaintiff's Complaint. 5, Plaintiff asks this Court to enter a default against Defendant, SUZANNE A. LEVENE A/K/A SUZANNE LEVENE pursuant to Fla, R. Civ. P. 1.500(b), which states: PHH14948-19/ase *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/12/2020 05:04:36 PM.****When a party against whom affirmative relief is sought has failed to plead or otherwise defend as provided by these rules or any applicable statute or any order of court, the court may enter a default against such party; provided that if such party has filed or served any paper in the action, that party shall be served with notice of the application for default. WHEREFORE, Plaintiff respectfully requests that this Court grant its Motion for Court Default, as well as for such further relief this Court deems just and proper. I HEREBY CERTIFY that a true and correct copy of the foregoing was sent to the parties and attorneys of record as shown on the attached service list. The service was completed on this iL day of ter be , 2020. On the service list, if an email address is designated for a party, then that party was served via email only. If no email address is listed for that defendant on the service list, then that party was served via regular U.S. Mail. VAN NESS LAW FIRM, PLC 1239 E. Newport Center Drive, Suite 110 Deerfield Beach, Florida 33442 Ph: (954) 571-2031 PRIMARY EMAIL: Pleadings@vanlawfl.com Jan D. Jagentorf-Esq. Bar Number: 33487 CASE NO: CACE-19-026084 SERVICE LIST ODALYS M, IBRAHUM, ESQ. IBRAHIM LAW P.A. 11200 PINES BLVD., SUITE 200 PEMBROKE PINES, FL 33026 ATTORNEY FOR SUZANNE A. LEVENE A/K/A SUZANNE LEVENE Email: pleadings@ibrahimlawpa.com ELAINE M. GATSOS, ESQ. LAW OFFICE OF ELAINE M. GATSOS 5541 N. UNIVERSITY DRIVE, SUITE 102 CORAL SPRINGS, FL 33067 ATTORNEY FOR OAKBROOK CONDOMINIUM ASSOCIATION, INC. Email: emgatsos@aol.com, realestategatsos@aol.com SYNCHRONY BANK F/K/A GE MONEY BANK, A CORPORATION F/K/A GE CAPITAL CONSUMER CARD CO. 140 WEKIVA SPRINGS RD LONGWOOD, FL 32779 PHH14948-19/asceFiling # 103157475 E-Filed 02/12/2020 02:30:45 AM Exhibit NAY IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE19026084 DIVISION 11. JUDGE Andrea Gundersen Deutsche Bank National Trust Company Plaintiff(s) / Petitioner(s) Vv. Suzanne A, Leven, et al Defendant(s) / Respondent(s) / AGREED ORDER ON DEFENDANT’S MOTION FOR ENLARGEMENT OF TIME THIS CAUSE came on to be heard on Defendant's Motion for Enlargement of Time to file a response to Complaint and the court being fully advised on the premises and the partied having agreed to the terms of this order, it is ORDERED AND ADJUDGED as follows: 41. Defendant shall have ten (10) days from the date of this order to file a responsive pleading to the complaint filed in this action. DONE and ORDERED in Chambers, at Broward County, Florida on 02-1 1-2020. oper giant oa ton o02rM CACE19026084 02-11-2020 6:02 PM Hon. Andrea Gundersen CIRCUIT JUDGE Electronically Signed by Andrea Gundersen Copies Furnished To: Elaine M Gatsos , E-mail : lauraphillipsemg@aol.com Elaine M Gatsos , E-mail : emgatsos@aol.com Elaine M Gatsos , E-mail : realestategatsos@aol.com John Anthony Van Ness , E-mail : E-Filing@vanlawfl.com Maya Rubinov , E-mail : pleadings@vanlawfl.com Odalys M. Ibrahim , E-mail : oibrahim@ibrahimlawpa.com Odalys M. Ibrahim , E-mail : kathy@ibrahimlawpa.com