On May 08, 2017 a
Trial Materials
was filed
involving a dispute between
U S Bank National Association Tr,
U.S. Bank, National Association Tr,
and
All Unknown Parties Claiming Interest,
Florida Housing Finance Corporation,
Mendzela, Robert,
Mendzela, Sweetheart,
Unknown Tenant No.1,
Unknown Tenant No.2,
for Circuit Civil
in the District Court of St. Lucie County.
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Filing # 66312687 E-Filed 01/09/2018 03:37:56 PM
IN THE CIRCUIT COURT OF THE NINETEENTH
JUDICIAL CIRCUIT IN AND FOR ST. LUCIE
COUNTY, FLORIDA. CIVIL DIVISION
CASE NO. 56-2017-CA-000774
U.S. BANK, NATIONAL ASSOCIATION AS
LEGAL TITLE TRUSTEE FOR TRUMAN 2016 SC6
TITLE TRUST,
Plaintiff,
VS.
ROBERT MENDZELA; et al.,
Defendants.
f
PLAINTIFE’S AMENDED WITNESS AND EXHIBIT LISTS
The Plaintiff, US. BANK, NATIONAL ASSOCIATION AS LEGAL TITLE
TRUSTEE FOR TRUMAN 2016 SC6 TITLE TRUST, by and through its undersigned counsel and
files the following Amended Witness and Exhibit Lists, pursuant to the Trial Order:
WIT.
5 LIS
1. Christopher Ly, Corporate Representative available for Rushmore Loan Management Services
LLC , as servicing agent to the owner of the note and mortgage
c/o SHD Legal Group P.A.
PO BOX 19519
Fort Lauderdale, FL 33318
This witness will testify as to the application of payments received, the default in payment, the
escrow advances if applicable, and the loan history of the Note and Mortgage which is the
subject matter of this action and any rebuttal of all defenses posed by any defendant in this
matter SHD Legal Group P.A. will make the trial witness available for deposition prior to trial,
time permitting, and will accept a Notice of Deposition addressed to the Corporate
Representative and served in care of SHD Legal Group P.A.2. Defendants/Borrowers ROBERT MENDZELA .
3. Any and all parties to this lawsuit.
4, Any and all witnesses identified in discovery.
5. Any and all witnesses listed and/or called and/or offered by any other party in this case.
6. Any and all rebuttal witnesses as necessary.
7. Plaintiff reserves the right to amend and/or supplement the above and foregoing list in the event
additional witnesses become known prior to trial or any witnesses have been inadvertently
omitted.
EXHIBIT LIST
1. Original Note and Mortgage, as well as any Assignment(s) of Mortgage.
2. Any documents related to the closing and origination of this loan, including the title policy.
3. Any documents reflecting Plaintiffs acquisition of the loan, and possession of the original
note, mortgage and assignment(s) of mortgage.
4. Any correspondence between the parties, or with third parties, related to the Note and
Mortgage
5. Demand letter(s) mailed to Borrowers/Defendants, and any business records pertaining to
same.
6. Collection history profile/servicing notes/servicing correspondence.
7. Loan Payment History/Summary/Spreadsheet.
8. Any documentation, including powers of attorney, servicing agreements or other
documentation establishing Plaintiff's authority to act on behalf of the owner of the note and mortgage
with respect to the mortgage and promissory note that are the basis of this action, including bringing this
foreclosure action.
9. Payoff Summary.
10. Late Charge/Expense Summary.
ll. Any and all exhibits identified and/or produced in discovery.12. Any and all pleadings in this action.
13. All applicable local, state and Federal statutes.
14. Any and all exhibits listed and/or offered by any of the parties to this case.
15. Any and all rebuttal exhibits as necessary.
16. Compilations and demonstrative exhibits related to any exhibits listed herein.
Plaintiff reserves the right to amend and/or supplement the above and foregoing list in the
event additional exhibits become known prior to trial or any exhibits have been inadvertently omitted.
Plaintiff shall not rely on any previously filed Affidavits, including Affidavits of Indebtedness.
All exhibits expected to be offered at trial by the Plaintiff, except those used for
impeachment, are hereby made available to the Defendants for examination upon reasonable prior
notice at a mutually convenient time.
CERTIFICATE OF SERVICE
THEREBY CERTIFY thata true and correct copy of the foregoing has been furnished by regular
USS. Mail, Facsimile or electronic mail this Gre January, 2018 to all parties on the attached service
list. All parties for whom an e-mail address has not been designated or a mailing address is not available
are hereby notified that a copy of the served document may be obtained, on request, from the clerk of the
court or from the party serving the document.
SHD Legal Group P.A.
Attorneys for Plaintiff
PO BOX 19519
Fort Lauderdale, FI, 33318
Telephone: (954) 564-0071
Facsimile: (954) 564-9252
Seryi ail: answers@shdlegalgroup.com
By: ——
Fazia 8. Corsbie
Florida Bar No. 978728
1460-161302
MB.SERVICE LIST
Case No. 56-2017-CA-000774
ROBERT MENDZELA
741 SW ASTER RD
PORT SAINT LUCIE, FL 34953
SWEETHEART MENDZELA
741 SW ASTER RD
PORT SAINT LUCIE, FL 34953
FLORIDA HOUSING FINANCE CORPORATION
President, Vice-President, or any other officer authorized to accept service
227 N Bronough St # 5000
Tallahassee, FL 32301
Document Filed Date
January 09, 2018
Case Filing Date
May 08, 2017
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Filing # 66312687 E-Filed 01/09/2018 03:37:56 PM IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR ST. LUCIE COUNTY, FLORIDA. CIVIL DIVISION CASE NO. 56-2017-CA-000774 U.S. BANK, NATIONAL ASSOCIATION AS LEGAL TITLE TRUSTEE FOR TRUMAN 2016 SC6 TITLE TRUST, Plaintiff, VS. ROBERT MENDZELA; et al., Defendants. f PLAINTIFE’S AMENDED WITNESS AND EXHIBIT LISTS The Plaintiff, US. BANK, NATIONAL ASSOCIATION AS LEGAL TITLE TRUSTEE FOR TRUMAN 2016 SC6 TITLE TRUST, by and through its undersigned counsel and files the following Amended Witness and Exhibit Lists, pursuant to the Trial Order: WIT. 5 LIS 1. Christopher Ly, Corporate Representative available for Rushmore Loan Management Services LLC , as servicing agent to the owner of the note and mortgage c/o SHD Legal Group P.A. PO BOX 19519 Fort Lauderdale, FL 33318 This witness will testify as to the application of payments received, the default in payment, the escrow advances if applicable, and the loan history of the Note and Mortgage which is the subject matter of this action and any rebuttal of all defenses posed by any defendant in this matter SHD Legal Group P.A. will make the trial witness available for deposition prior to trial, time permitting, and will accept a Notice of Deposition addressed to the Corporate Representative and served in care of SHD Legal Group P.A.2. Defendants/Borrowers ROBERT MENDZELA . 3. Any and all parties to this lawsuit. 4, Any and all witnesses identified in discovery. 5. Any and all witnesses listed and/or called and/or offered by any other party in this case. 6. Any and all rebuttal witnesses as necessary. 7. Plaintiff reserves the right to amend and/or supplement the above and foregoing list in the event additional witnesses become known prior to trial or any witnesses have been inadvertently omitted. EXHIBIT LIST 1. Original Note and Mortgage, as well as any Assignment(s) of Mortgage. 2. Any documents related to the closing and origination of this loan, including the title policy. 3. Any documents reflecting Plaintiffs acquisition of the loan, and possession of the original note, mortgage and assignment(s) of mortgage. 4. Any correspondence between the parties, or with third parties, related to the Note and Mortgage 5. Demand letter(s) mailed to Borrowers/Defendants, and any business records pertaining to same. 6. Collection history profile/servicing notes/servicing correspondence. 7. Loan Payment History/Summary/Spreadsheet. 8. Any documentation, including powers of attorney, servicing agreements or other documentation establishing Plaintiff's authority to act on behalf of the owner of the note and mortgage with respect to the mortgage and promissory note that are the basis of this action, including bringing this foreclosure action. 9. Payoff Summary. 10. Late Charge/Expense Summary. ll. Any and all exhibits identified and/or produced in discovery.12. Any and all pleadings in this action. 13. All applicable local, state and Federal statutes. 14. Any and all exhibits listed and/or offered by any of the parties to this case. 15. Any and all rebuttal exhibits as necessary. 16. Compilations and demonstrative exhibits related to any exhibits listed herein. Plaintiff reserves the right to amend and/or supplement the above and foregoing list in the event additional exhibits become known prior to trial or any exhibits have been inadvertently omitted. Plaintiff shall not rely on any previously filed Affidavits, including Affidavits of Indebtedness. All exhibits expected to be offered at trial by the Plaintiff, except those used for impeachment, are hereby made available to the Defendants for examination upon reasonable prior notice at a mutually convenient time. CERTIFICATE OF SERVICE THEREBY CERTIFY thata true and correct copy of the foregoing has been furnished by regular USS. Mail, Facsimile or electronic mail this Gre January, 2018 to all parties on the attached service list. All parties for whom an e-mail address has not been designated or a mailing address is not available are hereby notified that a copy of the served document may be obtained, on request, from the clerk of the court or from the party serving the document. SHD Legal Group P.A. Attorneys for Plaintiff PO BOX 19519 Fort Lauderdale, FI, 33318 Telephone: (954) 564-0071 Facsimile: (954) 564-9252 Seryi ail: answers@shdlegalgroup.com By: —— Fazia 8. Corsbie Florida Bar No. 978728 1460-161302 MB.SERVICE LIST Case No. 56-2017-CA-000774 ROBERT MENDZELA 741 SW ASTER RD PORT SAINT LUCIE, FL 34953 SWEETHEART MENDZELA 741 SW ASTER RD PORT SAINT LUCIE, FL 34953 FLORIDA HOUSING FINANCE CORPORATION President, Vice-President, or any other officer authorized to accept service 227 N Bronough St # 5000 Tallahassee, FL 32301