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Filing # 106284413 E-Filed 04/15/2020 02:17:42 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO.: 2019 CA 2732
AMERICAN FINANCIAL RESOURCES, INC., A
NEW JERSEY CORPORATION,
Plaintiff,
vs.
ROBERT A JOHNSON JR., ET AL.
Defendants.
/
DEFENDANT, JAKTHAN PROPERTIES, LLC’S UNOPPOSED
MOTION TO VACATE DEFAULT ENTERED FEBRUARY 6, 2020
COMES NOW, Defendant, JAKTHAN PROPERTIES, LLC, a Florida limited liability , by
and through undersigned counsel, and hereby files it’s Unopposed Motion to Vacate Default Entered
February 6, 2020 and in support thereof states:
1. The Complaint in this action was filed on or about December 17, 2019.
2. Defendant, JAKTHAN PROPERTIES, LLC, was served on or about January 2, 2020
and due to mistake, failed to file an Answer or Responsive Pleading within the twenty (20) day time
period as prescribed in the Summons.
3. On or about February 6, 2020, a Default was entered against JAKTHAN PROPERTIES,
LLC. [Doce. 32].
4. Plaintiff has reviewed this Motion and JAKTHAN PROPERTIES, LLC’s proposed
Answer to Complaint (attached hereto as Exhibit “A”) and has no objection to an entry of an Order
Vacating Default and deeming the JAKTHAN PROPERTIES, LLC’S Answer deemed as filed.
WHEREFORE, Defendant requests this Court to Grant Defendant Jakthan Properties, LLC’s
Unopposed Motion to Vacate Default Entered February 6, 2020, and deem the Answer attached as
Exhibit “A” as filed.
Schatt, McGraw, Rauba & Mutarelli, PA
Attorneys for Jakthan Properties LLC
328 N.E. 1% Avenue, Suite 100
Ocala, FL 34470
352-789-6520
Fla Bar No: 0115772
Richard MLaw.com
BY.
ufarelli, Jr., Esq.
Electronically Filed Marion Case # 19CA002732AX 04/15/2020 02:17:42 PMCERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of foregoing has been furnished via email and
regular mail this 15" day of April, 2020 to Joanne Galipault, Esq., eservice@clegalgroup.com; Robert
A. Johnson, Jr. and Virginia Johnson, 22721 NE 122th Terrace, Fort McCoy, FL 32134.IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT, IN AND FOR
MARION COUNTY, FLORIDA
CASE NO.: 2019 CA 2732
AMERICAN FINANCIAL RESOURCES, INC., A
NEW JERSEY CORPORATION,
Plaintiff,
VS.
ROBERT A JOHNSON JR., ET AL.
Defendants.
ANSWER
Comes now the Defendant, JAKTHAN PROPERTIES, LLC by and through undersigned
counsel and responds to the Verified Complaint for Foreclosure filed by Plaintiff, AMERICAN
FINANCIAL RESOURCES, INC., as follows:
Defendant, JAKTHAN PROPERTIES, LLC, hereby disclaims any interest in the real
property that is the subject of this litigation arising out of Final Judgment recorded in Official
Records Book 6890, Page 305 of the Public Records of Marion County, Florida, except from any
interest in surplus proceeds arising from the sale of the subject real property referenced in the
Complaint.
i
EXHIBIT
A
Schatt, McGraw, Rauba & Mutarelli, PA
Attorneys for Jakthan Properties, LLC
328 N.E. 1 Avenue, Suite 100
Ocala, FL 34470
(352) 789-6520
Richard Mutarelli, Jr., Esquire
Florida Bar No.: 0115772
Richard@SMRMLaw.com
BY <
Richard
li, Jr., ESQ.
——_——_Certificate of Service
I HEREBY CERTIFY that a true and correct copy of foregoing has been furnished via email and
regular mail this 15" day of April, 2020 to Joanne Galipault, Esq., eservice@clegalgroup.com;
Robert A. Johnson, Jr. and Virginia Johnson, 22721 NE 122th Terrace, Fort McCoy, FL 32134.
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Filing # 106284413 E-Filed 04/15/2020 02:17:42 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO.: 2019 CA 2732 AMERICAN FINANCIAL RESOURCES, INC., A NEW JERSEY CORPORATION, Plaintiff, vs. ROBERT A JOHNSON JR., ET AL. Defendants. / DEFENDANT, JAKTHAN PROPERTIES, LLC’S UNOPPOSED MOTION TO VACATE DEFAULT ENTERED FEBRUARY 6, 2020 COMES NOW, Defendant, JAKTHAN PROPERTIES, LLC, a Florida limited liability , by and through undersigned counsel, and hereby files it’s Unopposed Motion to Vacate Default Entered February 6, 2020 and in support thereof states: 1. The Complaint in this action was filed on or about December 17, 2019. 2. Defendant, JAKTHAN PROPERTIES, LLC, was served on or about January 2, 2020 and due to mistake, failed to file an Answer or Responsive Pleading within the twenty (20) day time period as prescribed in the Summons. 3. On or about February 6, 2020, a Default was entered against JAKTHAN PROPERTIES, LLC. [Doce. 32]. 4. Plaintiff has reviewed this Motion and JAKTHAN PROPERTIES, LLC’s proposed Answer to Complaint (attached hereto as Exhibit “A”) and has no objection to an entry of an Order Vacating Default and deeming the JAKTHAN PROPERTIES, LLC’S Answer deemed as filed. WHEREFORE, Defendant requests this Court to Grant Defendant Jakthan Properties, LLC’s Unopposed Motion to Vacate Default Entered February 6, 2020, and deem the Answer attached as Exhibit “A” as filed. Schatt, McGraw, Rauba & Mutarelli, PA Attorneys for Jakthan Properties LLC 328 N.E. 1% Avenue, Suite 100 Ocala, FL 34470 352-789-6520 Fla Bar No: 0115772 Richard MLaw.com BY. ufarelli, Jr., Esq. Electronically Filed Marion Case # 19CA002732AX 04/15/2020 02:17:42 PMCERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of foregoing has been furnished via email and regular mail this 15" day of April, 2020 to Joanne Galipault, Esq., eservice@clegalgroup.com; Robert A. Johnson, Jr. and Virginia Johnson, 22721 NE 122th Terrace, Fort McCoy, FL 32134.IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR MARION COUNTY, FLORIDA CASE NO.: 2019 CA 2732 AMERICAN FINANCIAL RESOURCES, INC., A NEW JERSEY CORPORATION, Plaintiff, VS. ROBERT A JOHNSON JR., ET AL. Defendants. ANSWER Comes now the Defendant, JAKTHAN PROPERTIES, LLC by and through undersigned counsel and responds to the Verified Complaint for Foreclosure filed by Plaintiff, AMERICAN FINANCIAL RESOURCES, INC., as follows: Defendant, JAKTHAN PROPERTIES, LLC, hereby disclaims any interest in the real property that is the subject of this litigation arising out of Final Judgment recorded in Official Records Book 6890, Page 305 of the Public Records of Marion County, Florida, except from any interest in surplus proceeds arising from the sale of the subject real property referenced in the Complaint. i EXHIBIT A Schatt, McGraw, Rauba & Mutarelli, PA Attorneys for Jakthan Properties, LLC 328 N.E. 1 Avenue, Suite 100 Ocala, FL 34470 (352) 789-6520 Richard Mutarelli, Jr., Esquire Florida Bar No.: 0115772 Richard@SMRMLaw.com BY < Richard li, Jr., ESQ. ——_——_Certificate of Service I HEREBY CERTIFY that a true and correct copy of foregoing has been furnished via email and regular mail this 15" day of April, 2020 to Joanne Galipault, Esq., eservice@clegalgroup.com; Robert A. Johnson, Jr. and Virginia Johnson, 22721 NE 122th Terrace, Fort McCoy, FL 32134.