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Filing # 102201751 E-Filed 01/24/2020 03:11:31 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL ACTION
PATCH OF LAND, LLC #201500001,
Plaintiff,
vs. CASE NO.: CACE-19-021053
DIVISION:
GRECO PROPERTIES, LLC, A NORTH
CAROLINA LIMITED LIABILITY
COMPANY, et al.,
Defendant(s).
/
AFFIDAVIT FOR CONSTRUCTIVE SERVICE OF C CRAIG EDWAARD, INC,
STATE OF FLORIDA
COUNTY OF PINELLAS
I, Damian G. Waldman, Esquire, being duly sworn on oath, deposes and states as follows:
1, That I am authorized to execute this affidavit as attorney for Plaintiff.
2. That this affidavit is executed for the purpose of service of process by publication against
Defendant: c CRAIG EDWAARD, INC.
3. That the statements made herein are based on my review of the case file and an Affidavit
of Avoidance, which is attached hereto.
4. That affiant believes that there are persons who are or may be interested in the subject
matter of the action or preceding whose names are unknown to affiant.
[REMAINDER OF PAGE INTENTIONALLY LEFT BLANK]
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/24/2020 03:11:31 PM.****FURTHER AFFIANT SAYETH NOT
amian G. Waldman, Esq.
Florida Bar No. 0090502
O Nicholas M. Porras, Esq.
Florida Bar No. 74822
O Farha Ahmed, Esq.
Florida Bar No. 113222
O Corey W. Szalai, Esq.
Florida Bar No. 1018220
Law Offices of Damian G. Waldman, P.A.
PO Box 5162
Largo, FL 33779
Telephone: (727) 538-4160
Facsimile: (727) 240-4972
Email 1: damian@dwaldmanlaw.com
Email 2: nick@dwaidmanlaw.com
Email 3: farha@dwaldmanlaw.com
Email 4: corey@dwaldmanlaw.com
E-Service: service@dwaldmanlaw.com
Attorneys for Plaintiff
SWORN TO AND SUBSCRIBED before me this ol day of _ Si Age 7
2020 by Damian G. Waldman, who is personally known to me and who did take an oath.
Notary Public
LYNNE F. VANHOOZEN
Notary Public - State of Florida
Commission # GG 919580
My Comm, Expires Dec 19, 2023
Bonded through National Notary Assn.Filing # 102187973 E-Filed 01/24/2020 01:31:26 PM
ALrIDAVIL UF AVUIDANGE
State of Florida County of Broward Circuit Court
Case Number: CACE-19-21053.
Plaintiff:
PATCH OF LAND, LLC #201500001
vs.
Defendant
GRECO PROPERTIES, LLC.., et al.
For:
Damian G. Waldman
THE LAW OFFICES OF DAMIAN G. WALDMAN, P.A.,
14010 Roosevelt Boulevard
Suite 701
Clearwater, FL 33762
Received by Caplan, Caplan & Caplan Process Servers on the 22nd day of October, 2019 at 3:49 pm to be served on C CRAIG
EDWAARD, INC., 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315.
|, Robin Pennington, being duly swom, depose and say that on the 20th day of January, 2020 at 3:08 pm, I:
1. Affiant is over the age of 18 and A Certified Process Server in good stand in the state of Florida
2. The contents of this affidavit are from affiant’s own personal knowledge and would testify to the following:
3. _Affiant received this Civil Action Summons, Notice of Lis Pendens, Verified Mortgage Foreclosure Complaint,
Certification of Possession of Original Note and Exhibits on the___' | a2 { 19, and made the due and
diligent attempts to serve the Defendant C CRAIG EDWAARD, INC., at the place of Residence as provided.
1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315
Non served for the following reason:
Affiant shows the Defendant conceals himself or herself so that process cannot be personally served, and that Affiant believes that
there is no person in the state upon whom service of process would bind said absent or concealed defendant. The defendant is
avoiding service. Defendant C CRAIG EDWAARD, INC., is avoiding service, due to numerous attempts made to serve the
defendant.
Affiant has made 8 or more attempts to serve the Defendant C CRAIG EDWAARD, INC., at his or her place of Residence. 1447
SW 4TH AVENUE, FORT LAUDERDALE, FL 33315.
Additional Information pertaining to this Service:
11/1/2019 11:50 am Attempted service at 1998 E SUNRISE BLVD., FORT LAUDERDALE, FL 33304, tenant here is Finn Real
Estate, registered agent doesn't work here, his son has his real estate license here but doesn't work in the office,
11/5/2019 11:37 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, private residence.
cannot tell if occupied. property next door is under construction.
11/9/2019 11:38 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, car in driveway, no
answer at residence, Will continue attempts. FL TAG #110YJN.
11/18/2019 7:04 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence
Same vehicle. cannot see lights on inside.
11/23/2019 12:42 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at
residence. same vehicle noted previously parked in driveway
12/2I2019 9:30 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence.
‘same vehicle noted previously parked in driveway plus vehicle with temporary tag. No answer at neighbor residence.
12/6/2019 7:58 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 39315, car in driveway, no
answer at residence. same vehicle noted previously.
1212/2019 1:26 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, same vehicles. No
answer at residence. No helpful neighbors.
12/16/2019 5:44 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, car in driveway, no
answer at residence. same vehicle noted previously parked in driveway.
12/18/2019 2:05 pm VEHICLE PARKED OUTSIDE BELONGS TO
Description: Gray 2017 Ford Explorer - 4 Dr Wagon Sport Utility
State of Origin: FLORIDA
VIN: 1FM5K7D82HGB87619
Data Source: Governmental
Registrant(s):AFFIDAVIT OF AVOIDANCE For CACE-19-21053
Company Name: C CRAIG EDEWAARD INC.
Address: 1998 E SUNRISE BLVD, FORT LAUDERDALE, FL 33304-1462
‘Tag Number: 110YJN
Issue State: FLORIDA
Earliest Registration Date: 02/08/2017
Latest Registration Date: 11/08/2018
Record Type: CURRENT
Previous Tag Number: 110YJN
Previous Issue State: FLORIDA
Lessee(s):
Company Name: C CRAIG EDEWAARD INC.
Potential SSN :
Address: 1998 E SUNRISE BLVD, FORT LAUDERDALE, FL 33304-1462
12/21/2019 11:50 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL. 33316, car in driveway, no
answer at residence, No answer, left card. Christmas wreath on door. Defendant vehicle parked in driveway.
12/23/2019 7.23 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence.
No call from contact information. Same vehicle.
12/28/2019 8:36 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence.
Same vehicle,
1/3/2020 1:38 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence, No
call from contact information.
1/6/2020 7:53 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence.
Vehicle registered to defendant parked in driveway. No call from contact information
Under penalty of perjury, | declare that | have read the foregoing and that the facts stated in it are true, that | am a Sheriff
Appointed Process Server in the county in which this defendant/witness was served and have no interest in the above action.
Pursuant to FS 92.525(2) and 28 USC Section 1746, no notary is required.
STATE OF FLORIDA . 2
Rotin Pennington
Subscribed and Sworn to before me on the 20th day of 727
January, 2020 by thé lant who is personally known to me.
Caplan, Caplan & Caplan Process Servers
42555 Orange Drive
Suite 106
Davie, FL 33330
NOTARY PUBLIC
MICHAEL RAMIREZ (305) 374-3426
Notary Public - State of Florida
ait Nor 2 Our Job Serial Number: CPN-2019036812
Jy Comm. Expires Nov 7, 2021
Bonded through Naciona: No:ary ASS
Service Fee:
Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox V8.0nFiling # 96988966 E-Filed 10/09/2019 02:27:10 PM
Case Number: CACE-19-021053 Division: 13
OCT 22 2019
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CIVIL ACTION
PATCH OF LAND, LLC #201500001,
Plaintiff, CASE atacole-peacte-oe Slee
DIVISI
vs.
tr TIME 7
GRECO PROPERTIES, LLC, A NORTH
CAROLINA LIMITED LIABILITY
COMPANY, et al., ITLA ___. JADGEr _- ~
Defendants.
CIVIL ACTION SUMMONS
THE STATE OF FLORIDA:
TO EACH SHERIFF OF THE STATE:
YOU ARE COMMANDED to serve this Summons and a copy of the Complaint and Notice of
Lis Pendens in this lawsuit upon the below-named Defendant:
C CRAIG EDWAARD, INC.
1998 F Sunrise Blvd.
re. Fort Laud, ole fy 35
IMPORTANT
The defendant is required to serve written defenses to the complaint on Damian G. Waldman,
Esq., whose address is shown below, within (20) days after service of this summons on that defendant,
exclusive of the day of service, and to file the original of the defenses with the clerk of this court either
before service on plaintiff's attomey or immediately thereafter. If a defendant fails to do so, a default will
be entered against that defendant for the relief demanded in the complaint.
PLAINTIFF/PLAINTIFE'S ATTORNEY:
Damian G. Waldman, Esq. EXPEDITE:
Law Offices of Damian G. Waldman, P.A. FIDELITY
PO Box 5162
Largo, FL 33779
(727) 538-4160
DATED on OCT 22 2019
Clerk of Circuit Court
By:
*#* FILED: BROWARD COUNTY, FL BRENDA
by 10/09/2019 02:27:08 PM.**** -) . yw
AUS)|Z
as
Se 2) 14447 Sw fi, AV.
Preview
Filing # 102201751 E-Filed 01/24/2020 03:11:31 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL ACTION PATCH OF LAND, LLC #201500001, Plaintiff, vs. CASE NO.: CACE-19-021053 DIVISION: GRECO PROPERTIES, LLC, A NORTH CAROLINA LIMITED LIABILITY COMPANY, et al., Defendant(s). / AFFIDAVIT FOR CONSTRUCTIVE SERVICE OF C CRAIG EDWAARD, INC, STATE OF FLORIDA COUNTY OF PINELLAS I, Damian G. Waldman, Esquire, being duly sworn on oath, deposes and states as follows: 1, That I am authorized to execute this affidavit as attorney for Plaintiff. 2. That this affidavit is executed for the purpose of service of process by publication against Defendant: c CRAIG EDWAARD, INC. 3. That the statements made herein are based on my review of the case file and an Affidavit of Avoidance, which is attached hereto. 4. That affiant believes that there are persons who are or may be interested in the subject matter of the action or preceding whose names are unknown to affiant. [REMAINDER OF PAGE INTENTIONALLY LEFT BLANK] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/24/2020 03:11:31 PM.****FURTHER AFFIANT SAYETH NOT amian G. Waldman, Esq. Florida Bar No. 0090502 O Nicholas M. Porras, Esq. Florida Bar No. 74822 O Farha Ahmed, Esq. Florida Bar No. 113222 O Corey W. Szalai, Esq. Florida Bar No. 1018220 Law Offices of Damian G. Waldman, P.A. PO Box 5162 Largo, FL 33779 Telephone: (727) 538-4160 Facsimile: (727) 240-4972 Email 1: damian@dwaldmanlaw.com Email 2: nick@dwaidmanlaw.com Email 3: farha@dwaldmanlaw.com Email 4: corey@dwaldmanlaw.com E-Service: service@dwaldmanlaw.com Attorneys for Plaintiff SWORN TO AND SUBSCRIBED before me this ol day of _ Si Age 7 2020 by Damian G. Waldman, who is personally known to me and who did take an oath. Notary Public LYNNE F. VANHOOZEN Notary Public - State of Florida Commission # GG 919580 My Comm, Expires Dec 19, 2023 Bonded through National Notary Assn.Filing # 102187973 E-Filed 01/24/2020 01:31:26 PM ALrIDAVIL UF AVUIDANGE State of Florida County of Broward Circuit Court Case Number: CACE-19-21053. Plaintiff: PATCH OF LAND, LLC #201500001 vs. Defendant GRECO PROPERTIES, LLC.., et al. For: Damian G. Waldman THE LAW OFFICES OF DAMIAN G. WALDMAN, P.A., 14010 Roosevelt Boulevard Suite 701 Clearwater, FL 33762 Received by Caplan, Caplan & Caplan Process Servers on the 22nd day of October, 2019 at 3:49 pm to be served on C CRAIG EDWAARD, INC., 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315. |, Robin Pennington, being duly swom, depose and say that on the 20th day of January, 2020 at 3:08 pm, I: 1. Affiant is over the age of 18 and A Certified Process Server in good stand in the state of Florida 2. The contents of this affidavit are from affiant’s own personal knowledge and would testify to the following: 3. _Affiant received this Civil Action Summons, Notice of Lis Pendens, Verified Mortgage Foreclosure Complaint, Certification of Possession of Original Note and Exhibits on the___' | a2 { 19, and made the due and diligent attempts to serve the Defendant C CRAIG EDWAARD, INC., at the place of Residence as provided. 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315 Non served for the following reason: Affiant shows the Defendant conceals himself or herself so that process cannot be personally served, and that Affiant believes that there is no person in the state upon whom service of process would bind said absent or concealed defendant. The defendant is avoiding service. Defendant C CRAIG EDWAARD, INC., is avoiding service, due to numerous attempts made to serve the defendant. Affiant has made 8 or more attempts to serve the Defendant C CRAIG EDWAARD, INC., at his or her place of Residence. 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315. Additional Information pertaining to this Service: 11/1/2019 11:50 am Attempted service at 1998 E SUNRISE BLVD., FORT LAUDERDALE, FL 33304, tenant here is Finn Real Estate, registered agent doesn't work here, his son has his real estate license here but doesn't work in the office, 11/5/2019 11:37 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, private residence. cannot tell if occupied. property next door is under construction. 11/9/2019 11:38 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, car in driveway, no answer at residence, Will continue attempts. FL TAG #110YJN. 11/18/2019 7:04 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence Same vehicle. cannot see lights on inside. 11/23/2019 12:42 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence. same vehicle noted previously parked in driveway 12/2I2019 9:30 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence. ‘same vehicle noted previously parked in driveway plus vehicle with temporary tag. No answer at neighbor residence. 12/6/2019 7:58 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 39315, car in driveway, no answer at residence. same vehicle noted previously. 1212/2019 1:26 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, same vehicles. No answer at residence. No helpful neighbors. 12/16/2019 5:44 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, car in driveway, no answer at residence. same vehicle noted previously parked in driveway. 12/18/2019 2:05 pm VEHICLE PARKED OUTSIDE BELONGS TO Description: Gray 2017 Ford Explorer - 4 Dr Wagon Sport Utility State of Origin: FLORIDA VIN: 1FM5K7D82HGB87619 Data Source: Governmental Registrant(s):AFFIDAVIT OF AVOIDANCE For CACE-19-21053 Company Name: C CRAIG EDEWAARD INC. Address: 1998 E SUNRISE BLVD, FORT LAUDERDALE, FL 33304-1462 ‘Tag Number: 110YJN Issue State: FLORIDA Earliest Registration Date: 02/08/2017 Latest Registration Date: 11/08/2018 Record Type: CURRENT Previous Tag Number: 110YJN Previous Issue State: FLORIDA Lessee(s): Company Name: C CRAIG EDEWAARD INC. Potential SSN : Address: 1998 E SUNRISE BLVD, FORT LAUDERDALE, FL 33304-1462 12/21/2019 11:50 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL. 33316, car in driveway, no answer at residence, No answer, left card. Christmas wreath on door. Defendant vehicle parked in driveway. 12/23/2019 7.23 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence. No call from contact information. Same vehicle. 12/28/2019 8:36 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence. Same vehicle, 1/3/2020 1:38 pm Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence, No call from contact information. 1/6/2020 7:53 am Attempted service at 1447 SW 4TH AVENUE, FORT LAUDERDALE, FL 33315, no answer at residence. Vehicle registered to defendant parked in driveway. No call from contact information Under penalty of perjury, | declare that | have read the foregoing and that the facts stated in it are true, that | am a Sheriff Appointed Process Server in the county in which this defendant/witness was served and have no interest in the above action. Pursuant to FS 92.525(2) and 28 USC Section 1746, no notary is required. STATE OF FLORIDA . 2 Rotin Pennington Subscribed and Sworn to before me on the 20th day of 727 January, 2020 by thé lant who is personally known to me. Caplan, Caplan & Caplan Process Servers 42555 Orange Drive Suite 106 Davie, FL 33330 NOTARY PUBLIC MICHAEL RAMIREZ (305) 374-3426 Notary Public - State of Florida ait Nor 2 Our Job Serial Number: CPN-2019036812 Jy Comm. Expires Nov 7, 2021 Bonded through Naciona: No:ary ASS Service Fee: Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbox V8.0nFiling # 96988966 E-Filed 10/09/2019 02:27:10 PM Case Number: CACE-19-021053 Division: 13 OCT 22 2019 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CIVIL ACTION PATCH OF LAND, LLC #201500001, Plaintiff, CASE atacole-peacte-oe Slee DIVISI vs. tr TIME 7 GRECO PROPERTIES, LLC, A NORTH CAROLINA LIMITED LIABILITY COMPANY, et al., ITLA ___. JADGEr _- ~ Defendants. CIVIL ACTION SUMMONS THE STATE OF FLORIDA: TO EACH SHERIFF OF THE STATE: YOU ARE COMMANDED to serve this Summons and a copy of the Complaint and Notice of Lis Pendens in this lawsuit upon the below-named Defendant: C CRAIG EDWAARD, INC. 1998 F Sunrise Blvd. re. Fort Laud, ole fy 35 IMPORTANT The defendant is required to serve written defenses to the complaint on Damian G. Waldman, Esq., whose address is shown below, within (20) days after service of this summons on that defendant, exclusive of the day of service, and to file the original of the defenses with the clerk of this court either before service on plaintiff's attomey or immediately thereafter. If a defendant fails to do so, a default will be entered against that defendant for the relief demanded in the complaint. PLAINTIFF/PLAINTIFE'S ATTORNEY: Damian G. Waldman, Esq. EXPEDITE: Law Offices of Damian G. Waldman, P.A. FIDELITY PO Box 5162 Largo, FL 33779 (727) 538-4160 DATED on OCT 22 2019 Clerk of Circuit Court By: *#* FILED: BROWARD COUNTY, FL BRENDA by 10/09/2019 02:27:08 PM.**** -) . yw AUS)|Z as Se 2) 14447 Sw fi, AV.