On December 28, 2009 a
Motion,Ex Parte
was filed
involving a dispute between
Wells Fargo Bank Na,
and
Bristol Pines Community Association Inc,
Ruiz, Larysa,
Ruiz, Walter,
Tenant #1,
Tenant #2,
Tenant #3,
Tenant #4,
Tikal Investment Company-Dissolved,
for Real Property Mortgage Foreclosure
in the District Court of Collier County.
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY, FLORIDA
CIVIL ACTION se 3
=< 2 =
WELLS FARGO BANK, NA, a 8
Plaintiff,
CASE NO.: 11-2009-CA-011019
vs. DIVISION: ¢ 3
TIKAL INVESTMENT COMPANY - DISSOLVED , et al, . € =
Defendant(s). a =
£
a
f «
MOTION FOR LEAVE TO FILE
AMENDED MORTGAGE FORECLOSURE COMPLAINT.
Plaintiff, WELLS FARGO BANK, NA, by and through its undersigned counsel, files this its Motion for
Leave to File Amended Mortgage Foreclosure Complaint, and as grounds therefore shows:
I. Plaintiff has recently leamed of the existence of an additional party with a possible interest in the
property that is the subject of this action.
2. BRISTOL PINES COMMUNITY ASSOCIATION, INC. may have an interest in the subject
property by virtue of any lien filed pursuant to the Declaration of Covenants and Restrictions and any amendments
thereto, of the Public Records of COLLIER County, Florida.
3. The existing Defendants will suffer no prejudice as a result of the proposed Amended Mortgage
Foreclosure Complaint, the original of which is attached.
Serial: 18538945
FILE_NUMBER: F09124409 DOC_ID: M012000
AIMUL IIIT
vaworg ‘AANNOD 4317109
v# O34WHEREFORE, Plaintiff requests that this Court enter an Order Granting Leave to File an Amended
Mortgage Foreclosure Complaint.
DATED this Xe /_ day of September, 2011.
Florida Default Law Group, P.L.
P.O. Box 25018
Tampa, Florida 33622-5018
(813) 251-4766
Florida Bar No. 84094
oO Donata S. Suplee
Florida Bar No. 37865
0 Kristia M. Bared
Florida Bar No. 14962
CERTIFICATE OF SERVICE
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all
parties listed on the attached service list on this 7 /_ day of September, 2011.
Florida Default Law Group, P.L.
P.O. Box 25018
Tampa, Florida 33622-5018
Florida Bar No. 84094
0 Donata S. Suplee
Florida Bar No. 37865
©. Kristia M. Bared
Florida Bar No. 14962
F09124409 CON wy : Ge 2001 -(4 - OUOLY
Document Filed Date
September 23, 2011
Case Filing Date
December 28, 2009
Category
Real Property Mortgage Foreclosure
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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR COLLIER COUNTY, FLORIDA CIVIL ACTION se 3 =< 2 = WELLS FARGO BANK, NA, a 8 Plaintiff, CASE NO.: 11-2009-CA-011019 vs. DIVISION: ¢ 3 TIKAL INVESTMENT COMPANY - DISSOLVED , et al, . € = Defendant(s). a = £ a f « MOTION FOR LEAVE TO FILE AMENDED MORTGAGE FORECLOSURE COMPLAINT. Plaintiff, WELLS FARGO BANK, NA, by and through its undersigned counsel, files this its Motion for Leave to File Amended Mortgage Foreclosure Complaint, and as grounds therefore shows: I. Plaintiff has recently leamed of the existence of an additional party with a possible interest in the property that is the subject of this action. 2. BRISTOL PINES COMMUNITY ASSOCIATION, INC. may have an interest in the subject property by virtue of any lien filed pursuant to the Declaration of Covenants and Restrictions and any amendments thereto, of the Public Records of COLLIER County, Florida. 3. The existing Defendants will suffer no prejudice as a result of the proposed Amended Mortgage Foreclosure Complaint, the original of which is attached. Serial: 18538945 FILE_NUMBER: F09124409 DOC_ID: M012000 AIMUL IIIT vaworg ‘AANNOD 4317109 v# O34WHEREFORE, Plaintiff requests that this Court enter an Order Granting Leave to File an Amended Mortgage Foreclosure Complaint. DATED this Xe /_ day of September, 2011. Florida Default Law Group, P.L. P.O. Box 25018 Tampa, Florida 33622-5018 (813) 251-4766 Florida Bar No. 84094 oO Donata S. Suplee Florida Bar No. 37865 0 Kristia M. Bared Florida Bar No. 14962 CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all parties listed on the attached service list on this 7 /_ day of September, 2011. Florida Default Law Group, P.L. P.O. Box 25018 Tampa, Florida 33622-5018 Florida Bar No. 84094 0 Donata S. Suplee Florida Bar No. 37865 ©. Kristia M. Bared Florida Bar No. 14962 F09124409 CON wy : Ge 2001 -(4 - OUOLY