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Filing # 126055170 E-Filed 05/03/2021 03:25:36 PM
IN THE CIRCUIT COURT OF THE
898 FIFTH AVENUE SOUTH HOLDINGS, LLC, 20™ JUDICIAL CIRCUIT IN AND FOR
Plaintiffs), COLLIER COUNTY, FLORIDA
vs.
BAYSTAR HOLDINGS, LLC, KYLE D. CASE NO.: 11-2018-CA-002183-0001-XX
MCLAUGHLIN, DANAN JON DELSING,
Defendant(s),
and ANSWER OF GARNISHEE AND
BANK OF AMERICA, N.A., DEMAND TO PLAINTIFF FOR
Garnishee PAYMENT OF IRNEY’S.
SSS
Garnishee, BANK OF AMERICA, N.A., by its undersigned attorney, Answers the Writ
of Garnishment served on it as follows:
1. At the time of the service of the Writ of Gamishment, plus sufficient time not to
exceed one business day for Garnishee to act expeditiously on the Writ, and at the time of its
Answer and at all times between service and its Answer, Garnishee was not indebted to
Defendant(s), KYLE D. MCLAUGHLIN.
2. Garnishee’s records indicate the following account(s), which was/were closed
prior to the service of the Writ of Garnishment in this case:
Account Number(s) lame(s) on Account Date Account Closed
XXXX-XXXX-0638 Kyle D. McLaughlin 04/02/20
1378 Chesapeake Ave.
Naples, FL 34102-0511
3. Garnishee knows of no other person indebted to the Defendant(s) or any other
person who may have any effects, goods, money or chattels of the said Defendant(s) nor did
Garnishee have in its possession or control any other tangible or intangible personal property of
the Defendant(s).
4, In accordance with Section 77.28 as amended on July 1, 2014, and having filed
the Answer of Garnishee in this case, Garnishee hereby demands from Plaintiff the
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 05/03/2021 03:25:36 PMpayment forthwith of the $100.00 statutory garnishment fee for the part payment of its
attorney’s fees, to be made payable to The Noa Law Firm, P.A., Garnishee’s attorney(s), and to
be mailed to:
THE NOA LAW FIRM, P.A.
P.O. Box 941958
Miami, Florida 33194
WHEREFORE, Gamishee prays that this Court enter its judgment determining proper
disposition of any funds held pursuant to the Writ of Garnishment and demands payment by
Plaintiff forthwith of the $100.00 statutory garnishment fee as part payment of Garnishee’s
attorney’s fees, to be made payable to The Noa Law Firm, P.A., Garnishee’s attorney(s), and
for any other relief this Court deems just and proper.
DESIGNATION OF E) DDRESS
Pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, Counsel for
Garnishee hereby designates the following primary email address for service of court documents:
Primary email address: e-service@noalawfirm.com.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing was furnished via electronic mail
this__3®°_ day of _MAY __, 2021, to CHRISTIAN GARRETT HAMON, ESQ.,
ATTORNEY FOR PLAINTIFF, Email: chaman@dallagolaw.com
THE NOA LAW FIRM, P.A.
ATTORNEY(S) FOR GARNISHEE
P. O. Box 941958
Miami, Florida 33194
Telephone: (305)559-9620
Facsimile: (305)559-3611
By:
NOA, ESQ., FBN 729299
JOSEPH A. NOA, JR., ESQ., FBN 81984
{] MICHAEL A. NOA, ESQ., FBN 93621
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Filing # 126055170 E-Filed 05/03/2021 03:25:36 PM IN THE CIRCUIT COURT OF THE 898 FIFTH AVENUE SOUTH HOLDINGS, LLC, 20™ JUDICIAL CIRCUIT IN AND FOR Plaintiffs), COLLIER COUNTY, FLORIDA vs. BAYSTAR HOLDINGS, LLC, KYLE D. CASE NO.: 11-2018-CA-002183-0001-XX MCLAUGHLIN, DANAN JON DELSING, Defendant(s), and ANSWER OF GARNISHEE AND BANK OF AMERICA, N.A., DEMAND TO PLAINTIFF FOR Garnishee PAYMENT OF IRNEY’S. SSS Garnishee, BANK OF AMERICA, N.A., by its undersigned attorney, Answers the Writ of Garnishment served on it as follows: 1. At the time of the service of the Writ of Gamishment, plus sufficient time not to exceed one business day for Garnishee to act expeditiously on the Writ, and at the time of its Answer and at all times between service and its Answer, Garnishee was not indebted to Defendant(s), KYLE D. MCLAUGHLIN. 2. Garnishee’s records indicate the following account(s), which was/were closed prior to the service of the Writ of Garnishment in this case: Account Number(s) lame(s) on Account Date Account Closed XXXX-XXXX-0638 Kyle D. McLaughlin 04/02/20 1378 Chesapeake Ave. Naples, FL 34102-0511 3. Garnishee knows of no other person indebted to the Defendant(s) or any other person who may have any effects, goods, money or chattels of the said Defendant(s) nor did Garnishee have in its possession or control any other tangible or intangible personal property of the Defendant(s). 4, In accordance with Section 77.28 as amended on July 1, 2014, and having filed the Answer of Garnishee in this case, Garnishee hereby demands from Plaintiff the FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 05/03/2021 03:25:36 PMpayment forthwith of the $100.00 statutory garnishment fee for the part payment of its attorney’s fees, to be made payable to The Noa Law Firm, P.A., Garnishee’s attorney(s), and to be mailed to: THE NOA LAW FIRM, P.A. P.O. Box 941958 Miami, Florida 33194 WHEREFORE, Gamishee prays that this Court enter its judgment determining proper disposition of any funds held pursuant to the Writ of Garnishment and demands payment by Plaintiff forthwith of the $100.00 statutory garnishment fee as part payment of Garnishee’s attorney’s fees, to be made payable to The Noa Law Firm, P.A., Garnishee’s attorney(s), and for any other relief this Court deems just and proper. DESIGNATION OF E) DDRESS Pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, Counsel for Garnishee hereby designates the following primary email address for service of court documents: Primary email address: e-service@noalawfirm.com. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing was furnished via electronic mail this__3®°_ day of _MAY __, 2021, to CHRISTIAN GARRETT HAMON, ESQ., ATTORNEY FOR PLAINTIFF, Email: chaman@dallagolaw.com THE NOA LAW FIRM, P.A. ATTORNEY(S) FOR GARNISHEE P. O. Box 941958 Miami, Florida 33194 Telephone: (305)559-9620 Facsimile: (305)559-3611 By: NOA, ESQ., FBN 729299 JOSEPH A. NOA, JR., ESQ., FBN 81984 {] MICHAEL A. NOA, ESQ., FBN 93621