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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY
FIRST LIDO CONDOMINIUM, INC.,
A Florida not-for-profit corporation,
Plaintiffs,
VS.
CLO-ANN GARRISON and
BANK OF AMERICA, NA,
Defendants,
Case No.: 2014-CA-004931-NC
/
DEFENDANT’S MOTION TO STRIKE EMERGENCY PLAINTIFF’S MOTION TO RESET
FORECLOSURE SALE AND IN THE ALTERNATIVE MOTION FOR CONTINUANCE
COMES NOW the Defendant, CLO ANN GARRISON, Pro Se, files this Motion in response to
Plaintiff's Motion and as grounds therefore state(s):
BACKGROUND
1) Attorney Borden emailed Attorney Gugino unequivocal advice that he no longer represents the
Defendant on the instant case, yet Attorney Gugino sought to argue that Attorney Borden was
somehow obligated to be counsel, despite the docket’s reflection of dismissal from the case on
5/30/2015. EXHIBIT A
2) Attorney Joseph Gugino has practiced a serial pattern of intentionally excluding the Pro Se
Defendant Clo Ann Garrison the required service of process on May 18, 2017, August 28, 2017 and in
the instant motion on February 28, 2018 — as reflected on the filings in the record.
3) The Defendant asserts Attorney Gugino’s filings, intentionally withholding notice from the
Defendant and filing unsupported and frivolous emergency motions with this Court, are consistent
with the pattern of bad faith actions demonstrated by the Plaintiff in several negotiations and creates a
1
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL4)
5)
6)
9)
basis to award the Defendant attorney fees and further the Plaintiff should be subject consideration by
this Court for further sanctions to ensure this type of predatory behavior is not encouraged or
rewarded.
The Plaintiff's Bankruptcy Attorney, David Hicks, is aware the cause for dismissal are a result of
a misunderstanding and the Bankruptcy case is likely to be cured or otherwise clarified to result in
reinstatement of the Bankruptcy Case. By Federal Rule, the Defendant has 14 days to file such
actions for reconsideration.
The Plaintiff's filings are intended to game this Court’s resources for the Plaintiff's unjust
enrichment on the gamble that a quick foreclosure sale date can be achieved prior to the Defendant’s
ability to reinstate the Bankruptcy case.
The Defendant has offered adequate protection to the Plaintiff during the pendency of agreed upon
settlement negotiations between the parties, by virtue paying all monthly association dues since
January 2018.
Since at least February 5, 2018 Attorney Hicks and the Defendant (and representatives) have been
involved in mutually agreed upon settlement negotiations, wherein the Plaintiff agreed to hold a
meeting with the Defendant to attempt to arrive at a settlement. The Plaintiff represented to the
Federal Bankruptcy court the mutual agreement to continue the bankruptcy case in the pendency of
settlement negotiations.
Even in the case the Bankruptcy case was not to be reinstated, the Defendant has good cause to
assert lher rights before this Court and receive due process thereof.
FILING OF FRIVOLOUS EMERGENCY MOTIONS
Attorney Gugino’s filing of frivolous emergency motions (August 28, 2017 and the instant motion
2
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLon February 28, 2018) are in contravention of this Court’s requirements, Fla. R. Civ. P. 1.610(a) and
any reasonable basis for declaring an “Emergency”. It is obvious that Attorney Gugino is seeking to
gain an unfair advantage by attempting to disenfranchise the Defendant of her right to due process and
other rules governing procedure.
10) Attorney Gugino was formally advised by Attorney Borden that he is not representing the
Defendant on this case, no other attorney has entered a notice of representation and ongoing actions in
the Southern District of Florida, Federal Bankruptcy Court have been entirely Pro Se, his filings
amount to a Ex Parte action to gain an unfair advantage in the proceedings. EXHIBIT A
11) The docket on the instant case has reflected the dismissal of Attorney Borden at all times since
Attorney Gugino was hired to replace prior counsel for Plaintiff. There is simply no excuse or reason
to suggest excusable neglect on the part of Attorney Gugino, his actions are clearly intentional to harm
the Defendant and unjustly enrich the Plaintiff. EXHIBIT B
12) Plaintiff's Bankruptcy Attomey, David Hicks, is in daily and/or contemporaneous contact with
Attorney Gugino. Attorney Hicks is fully aware the Defendant is Pro Se and his filings with the
Federal Bankruptcy Court reflect this fact. At no time has Attorney Borden been noticed on any
filings on the current Bankruptcy case in the Southern District. Attorney Gugino has no excuse to
claim ignorance the Defendant is Pro Se and that Attorney Borden is not representing her on the
instant case. EXHIBIT C
13) | Granting an emergency motion without proper notice to the opposing party, absent a genuine
emergency, deprives the opposing party of procedural due process. No such motion may be granted
unless: ©
a). It appears from the specific facts shown by affidavit or verified pleading * that
immediate and irreparable injury, loss, or damage will result to the movant before the
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLadverse party can be heard in opposition; and
b). The movant’s attorney certifies in writing any efforts that have been made to give
notice and the reasons why notice should not be required.
14) Attorney Gugino has failed to adhere to any such requirements of Fla. R. Civ. P. 1.610(a).
15) This Court’s rules regarding Emergency hearings provides in part:
Sarasota County Residential Mortgage Foreclosures Contested and Uncontested Hearings
Information And Requirements
Emergency Hearings: Any emergency motion must be provided to the assigned judge’s Judicial
Assistant via fax or e-mail, with a cover letter requesting the amount of hearing time requested, as
well as a certification that states the Movant has contacted opposing counsel/party in a good
faith effort to resolve the issue. The Movant should call the Judicial Assistant to confirm
availability of a judge to review the motion. The Judicial Assistant does not provide emergency
hearing time without a judge’s authorization. The assigned division or duty judge will review
the motion and determine whether or not an expedited hearing will be granted.
16) There is no evidence of any certification stating the Movant’s basis for emergency status, contact
by the Movant with the opposing party whatsoever or any good faith effort to resolve the issue.
17) There is no evidence of any review by a judge to authorize the emergency hearing time that has
been provided.
IMPROPER SERVICE
18) The Plaintiff's Motion was never served upon the Defendant, who has established herself as Pro
Se on this case since at least May of 2017 with Attorney Gugino and by notice from Attorney Borden.
19) Defendant Clo Ann Garrison has not had required notice or reasonable time to retain counsel to
prepare for or attend a hearing on this case as required by the Florida Rules of Civil Procedure.
20) The Defendant has never been afforded mediation to facilitate communication and resolve the
disputes between the parties.
21) The Defendant requests the Motion for the March 7, 2018 hearing to be stricken based on the
intentional failure to provide proper notice to the Defendant.
4
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLMOTION FOR CONTINUANCE IN TE
E ve J Po ae Meet
wt. 4 Wao ¥
mre A me si Sih a MEARE hart tnt re hy: Slane a NAA i
22) In the case this Honorable Court denies this Motion to Strike the Plaintiff's Emergency Motion-to
hearing date.
23) __ Ifthe continuance is not granted Clo Ann Garrison will be unfairly prejudiced.
24) Acontinuance will not damage or unfairly prejudice the movant.or any pa
ties to this case. See
A.P.D, Holdings, Inc. v. Reidel, 86:
) So.2d 682. 684 (Fla. 4" DCA 2004) and Yaris v. F fartley 128
So.3d:825 (Fla. -¢" DCA 2013) EXHIBIT D
EFORE, Defendant respectfully request the Court to Strike the Emergency Plaintiff's Motion
to Reset Foreclosure Sale, award attorney fees to the Defendant based on the frivolous and baseless nature
of the Emergency status of the motion and the Plaintiff's intentional actions to deprive the Defendant of
ocess on the ins
due pr ant action, or in the alternative grant a 30-day continuance on the Hearing to Reset
the Foreclosure Sale and order the Plaintiff to re-notice the hearing properly, and further relief as this
220 RHI TSN enbhienieitrenstbedteenenennee stron
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLtrue and correct. copy of the foregoing has
ces of Welis / Olah VIA USPS o: or Hi
Raapaasine dn nena! * tat ‘ “eevee cs Ne mK Tt ie S"sectecceeeoseneeee 2 esol coseneecseeneecnsenpeodese sweety aos
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLEE
From: Joseph A. Gugino jgugino@kevinwellspa.com &
Subject: RE: Firs Lido v. Clo-Ann Garrison 2014-CA-004931-NC
Date: May 26, 2017 at 2:27 PM
To: Alan Borden Aborden@ 1800debtrelief.com
Allan Borden,
To the best of my knowledge you are the only attorney of record in the case of First Lido Condominium,
Inc. vs. Clo Ann Garrison. Additionally as of today you are the attorney of record according to the
docket for said case in Sarasota County.
Further you filed the Defendant Clo Ann Garrison’s Answer and Affirmative Defenses in the above case
on 11/18/2014 @ 4:29 PM; the Defendant’s Response to Plaintiff’s Motion for Summary Final
Judgment of Foreclosure as to Count | in the above case on 3/30/2015 @ 9:8:29 Pm; the last filed
Suggestion of the Pendency of Bankruptcy Proceedings Under Chapter 13 of the Bankruptcy Code filed .
in the above case on 3/28/2016 @ 1:30:34 PM; as well as additional pleadings in the above case. (See |
attachments)
There is no pleading on the Court docket showing your withdrawal from the above case.
Therefore, it appears you are the attorney of record for the defendant, Clo Ann Garrison.
If you have a question or concern, please let me know.
Very truly yours,
Joseph A. Gugino, Esq.
Law Offices of Wells | Olah, P.A.
1800 Second Street, Suite 808
Sarasota, FL 34236
(941) 366-9191 Telephone
JGugino@KevinWellspa.com
k.
EXHIBIT A
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLTHIS LAW FIRM MAY BE DEEMED A DEBT COLLECTOR AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTICE: This e-mail message and any attachment to this e-mail message
contain confidential information that may be legally privileged. If you are
not the intended recipient, you must not review, retransmit, print, copy, use
or disseminate this e-mail or any attachments to it. If you have received this
e-mail in error, please notify us immediately by return e-mail or by telephone
at (941) 366-9191 and delete this message. Please note that if this e-mail
message contains a forwarded message or is a reply to a prior message,
some or all of the contents of this message or any attachments may not
have been produced by the sender.
NOTICE TO HOMEOWNERS’ ASSOCIATION AND CONDOMINIUM
ASSOCIATION CLIENTS: This communication (and any attachments) may
include privileged communications between attorney and client that are
exempt from disclosure and/or protected pursuant to Sections 90.502,
718.111(12) and/or 720.303(4), Fla. Stat. In such event and to protect the
privileged nature of this communication, this communication should not be
placed in, or considered to be part of, the official records of an association
pursuant to Sections 718.111(12) or 720.303(4), Fla. Stat., as applicable,
until such time as the board of directors has determined to make its
contents public.
If you have an urgent communication or if you have not heard from me in
response to your e-mail, please telephone me immediately. DO NOT
ASSUME THAT YOUR E-MAIL HAS BEEN RECEIVED.
Me ORS NEE ROAR, SARA A ARMMARA LARA UR NR AA SOS te ari mn Ata eSB LAR AALS JON be eo San an ANAS Naan 8 AMMAR AAR SA AANA Ale MRA NRA APA 2 ON A RRR ARRON URINAL UMRAO MA AS a Pay nA mA RAY yy RE NN oh? MLAB ore tener dindnday aarbhRy AAA Annan AAMMAMYE Mb a AAA YY ane RA ARAN dineslia ean NANA A NSN Maine sini: mania Ate AAA ASE en IE wel,
From: Alan Borden [mailto: Aborden@1800debtrelief com]
Sent: Friday, May 26, 2017 2:01 PM
To: Joseph A. Gugino
Subject: Firs Lido v. Clo-Ann Garrison 2014-CA-004931-NC
| do not represent Mrs. Garrison in the above mentioned case, | wanted to make sure that your office is
aware that | should not be a barrier to speaking with the Defendant directly.
EXHIBIT A
Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLHelpful Tips ->
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_ 2014 CA 004931 Uniform Case
Case Number: NC Number:
582014CA004931XXXANC Case Status: REOP
Case File
Date: 08/22/2014 Case Close Date: 03/31/2015 Judge: MCHUGH, ANDREA
Party information
FIRST LIDO CONDOMINIUM, INC. A FLORIDA NOT-FOR-PROFIT laintif A AN OS /30n018
CORPORATION ainti ( )
GUGINO, JOSEPH (05/16/2017)
_GARRISON, CLO ANN Defendant ||BORDEN, ALAN (05/30/2015)
"BANK OF AM ERICA NA Defendant
HANSON, MARK
UNKNOWN TENANT IN POSSESSION, TENANT Defendant ALAN (05/30/2015)
UNKNOWN TENANT IN POSSESSION, TENANT “Defendant
SECRETARY OF HOUSING AND URBAN DEVELOPMENT Defendant
Case Events
02/19/2015 09:45 AM COURTROOM 6C MOTIONS
03/03/2015 01:30 PM COURTROOM 1 MOTIONS
eran tee teen serene
05/05/2015 09:00 AM COURTROOM ONLINE | JUDICIAL SALES
03/29/2016 —-—«| 09:00AM ~=—*«| COURTROOMONLINE ——i«™”
07/06/2017 09:00 AM COURTROOM ONLINE | JUDICIAL SALES
10/04/2017 09:00 AM COURTROOM ONLINE JUDICIAL SALES
Case Fees
JUDICIAL SALES - ELECTRONIC SALE FEE $70.00 $70.00 $0.00 $0.00
SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE | $10.00 | $10. 00 $0.00 $0.00
SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE $10.00 $10.00 $0.00 $0.00
"SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE | $10.00 | $10.00 ooo 8=8F—
Preview
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY FIRST LIDO CONDOMINIUM, INC., A Florida not-for-profit corporation, Plaintiffs, VS. CLO-ANN GARRISON and BANK OF AMERICA, NA, Defendants, Case No.: 2014-CA-004931-NC / DEFENDANT’S MOTION TO STRIKE EMERGENCY PLAINTIFF’S MOTION TO RESET FORECLOSURE SALE AND IN THE ALTERNATIVE MOTION FOR CONTINUANCE COMES NOW the Defendant, CLO ANN GARRISON, Pro Se, files this Motion in response to Plaintiff's Motion and as grounds therefore state(s): BACKGROUND 1) Attorney Borden emailed Attorney Gugino unequivocal advice that he no longer represents the Defendant on the instant case, yet Attorney Gugino sought to argue that Attorney Borden was somehow obligated to be counsel, despite the docket’s reflection of dismissal from the case on 5/30/2015. EXHIBIT A 2) Attorney Joseph Gugino has practiced a serial pattern of intentionally excluding the Pro Se Defendant Clo Ann Garrison the required service of process on May 18, 2017, August 28, 2017 and in the instant motion on February 28, 2018 — as reflected on the filings in the record. 3) The Defendant asserts Attorney Gugino’s filings, intentionally withholding notice from the Defendant and filing unsupported and frivolous emergency motions with this Court, are consistent with the pattern of bad faith actions demonstrated by the Plaintiff in several negotiations and creates a 1 Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL4) 5) 6) 9) basis to award the Defendant attorney fees and further the Plaintiff should be subject consideration by this Court for further sanctions to ensure this type of predatory behavior is not encouraged or rewarded. The Plaintiff's Bankruptcy Attorney, David Hicks, is aware the cause for dismissal are a result of a misunderstanding and the Bankruptcy case is likely to be cured or otherwise clarified to result in reinstatement of the Bankruptcy Case. By Federal Rule, the Defendant has 14 days to file such actions for reconsideration. The Plaintiff's filings are intended to game this Court’s resources for the Plaintiff's unjust enrichment on the gamble that a quick foreclosure sale date can be achieved prior to the Defendant’s ability to reinstate the Bankruptcy case. The Defendant has offered adequate protection to the Plaintiff during the pendency of agreed upon settlement negotiations between the parties, by virtue paying all monthly association dues since January 2018. Since at least February 5, 2018 Attorney Hicks and the Defendant (and representatives) have been involved in mutually agreed upon settlement negotiations, wherein the Plaintiff agreed to hold a meeting with the Defendant to attempt to arrive at a settlement. The Plaintiff represented to the Federal Bankruptcy court the mutual agreement to continue the bankruptcy case in the pendency of settlement negotiations. Even in the case the Bankruptcy case was not to be reinstated, the Defendant has good cause to assert lher rights before this Court and receive due process thereof. FILING OF FRIVOLOUS EMERGENCY MOTIONS Attorney Gugino’s filing of frivolous emergency motions (August 28, 2017 and the instant motion 2 Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLon February 28, 2018) are in contravention of this Court’s requirements, Fla. R. Civ. P. 1.610(a) and any reasonable basis for declaring an “Emergency”. It is obvious that Attorney Gugino is seeking to gain an unfair advantage by attempting to disenfranchise the Defendant of her right to due process and other rules governing procedure. 10) Attorney Gugino was formally advised by Attorney Borden that he is not representing the Defendant on this case, no other attorney has entered a notice of representation and ongoing actions in the Southern District of Florida, Federal Bankruptcy Court have been entirely Pro Se, his filings amount to a Ex Parte action to gain an unfair advantage in the proceedings. EXHIBIT A 11) The docket on the instant case has reflected the dismissal of Attorney Borden at all times since Attorney Gugino was hired to replace prior counsel for Plaintiff. There is simply no excuse or reason to suggest excusable neglect on the part of Attorney Gugino, his actions are clearly intentional to harm the Defendant and unjustly enrich the Plaintiff. EXHIBIT B 12) Plaintiff's Bankruptcy Attomey, David Hicks, is in daily and/or contemporaneous contact with Attorney Gugino. Attorney Hicks is fully aware the Defendant is Pro Se and his filings with the Federal Bankruptcy Court reflect this fact. At no time has Attorney Borden been noticed on any filings on the current Bankruptcy case in the Southern District. Attorney Gugino has no excuse to claim ignorance the Defendant is Pro Se and that Attorney Borden is not representing her on the instant case. EXHIBIT C 13) | Granting an emergency motion without proper notice to the opposing party, absent a genuine emergency, deprives the opposing party of procedural due process. No such motion may be granted unless: © a). It appears from the specific facts shown by affidavit or verified pleading * that immediate and irreparable injury, loss, or damage will result to the movant before the Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLadverse party can be heard in opposition; and b). The movant’s attorney certifies in writing any efforts that have been made to give notice and the reasons why notice should not be required. 14) Attorney Gugino has failed to adhere to any such requirements of Fla. R. Civ. P. 1.610(a). 15) This Court’s rules regarding Emergency hearings provides in part: Sarasota County Residential Mortgage Foreclosures Contested and Uncontested Hearings Information And Requirements Emergency Hearings: Any emergency motion must be provided to the assigned judge’s Judicial Assistant via fax or e-mail, with a cover letter requesting the amount of hearing time requested, as well as a certification that states the Movant has contacted opposing counsel/party in a good faith effort to resolve the issue. The Movant should call the Judicial Assistant to confirm availability of a judge to review the motion. The Judicial Assistant does not provide emergency hearing time without a judge’s authorization. The assigned division or duty judge will review the motion and determine whether or not an expedited hearing will be granted. 16) There is no evidence of any certification stating the Movant’s basis for emergency status, contact by the Movant with the opposing party whatsoever or any good faith effort to resolve the issue. 17) There is no evidence of any review by a judge to authorize the emergency hearing time that has been provided. IMPROPER SERVICE 18) The Plaintiff's Motion was never served upon the Defendant, who has established herself as Pro Se on this case since at least May of 2017 with Attorney Gugino and by notice from Attorney Borden. 19) Defendant Clo Ann Garrison has not had required notice or reasonable time to retain counsel to prepare for or attend a hearing on this case as required by the Florida Rules of Civil Procedure. 20) The Defendant has never been afforded mediation to facilitate communication and resolve the disputes between the parties. 21) The Defendant requests the Motion for the March 7, 2018 hearing to be stricken based on the intentional failure to provide proper notice to the Defendant. 4 Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLMOTION FOR CONTINUANCE IN TE E ve J Po ae Meet wt. 4 Wao ¥ mre A me si Sih a MEARE hart tnt re hy: Slane a NAA i 22) In the case this Honorable Court denies this Motion to Strike the Plaintiff's Emergency Motion-to hearing date. 23) __ Ifthe continuance is not granted Clo Ann Garrison will be unfairly prejudiced. 24) Acontinuance will not damage or unfairly prejudice the movant.or any pa ties to this case. See A.P.D, Holdings, Inc. v. Reidel, 86: ) So.2d 682. 684 (Fla. 4" DCA 2004) and Yaris v. F fartley 128 So.3d:825 (Fla. -¢" DCA 2013) EXHIBIT D EFORE, Defendant respectfully request the Court to Strike the Emergency Plaintiff's Motion to Reset Foreclosure Sale, award attorney fees to the Defendant based on the frivolous and baseless nature of the Emergency status of the motion and the Plaintiff's intentional actions to deprive the Defendant of ocess on the ins due pr ant action, or in the alternative grant a 30-day continuance on the Hearing to Reset the Foreclosure Sale and order the Plaintiff to re-notice the hearing properly, and further relief as this 220 RHI TSN enbhienieitrenstbedteenenennee stron Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLtrue and correct. copy of the foregoing has ces of Welis / Olah VIA USPS o: or Hi Raapaasine dn nena! * tat ‘ “eevee cs Ne mK Tt ie S"sectecceeeoseneeee 2 esol coseneecseeneecnsenpeodese sweety aos Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLEE From: Joseph A. Gugino jgugino@kevinwellspa.com & Subject: RE: Firs Lido v. Clo-Ann Garrison 2014-CA-004931-NC Date: May 26, 2017 at 2:27 PM To: Alan Borden Aborden@ 1800debtrelief.com Allan Borden, To the best of my knowledge you are the only attorney of record in the case of First Lido Condominium, Inc. vs. Clo Ann Garrison. Additionally as of today you are the attorney of record according to the docket for said case in Sarasota County. Further you filed the Defendant Clo Ann Garrison’s Answer and Affirmative Defenses in the above case on 11/18/2014 @ 4:29 PM; the Defendant’s Response to Plaintiff’s Motion for Summary Final Judgment of Foreclosure as to Count | in the above case on 3/30/2015 @ 9:8:29 Pm; the last filed Suggestion of the Pendency of Bankruptcy Proceedings Under Chapter 13 of the Bankruptcy Code filed . in the above case on 3/28/2016 @ 1:30:34 PM; as well as additional pleadings in the above case. (See | attachments) There is no pleading on the Court docket showing your withdrawal from the above case. Therefore, it appears you are the attorney of record for the defendant, Clo Ann Garrison. If you have a question or concern, please let me know. Very truly yours, Joseph A. Gugino, Esq. Law Offices of Wells | Olah, P.A. 1800 Second Street, Suite 808 Sarasota, FL 34236 (941) 366-9191 Telephone JGugino@KevinWellspa.com k. EXHIBIT A Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLTHIS LAW FIRM MAY BE DEEMED A DEBT COLLECTOR AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE: This e-mail message and any attachment to this e-mail message contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, print, copy, use or disseminate this e-mail or any attachments to it. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone at (941) 366-9191 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by the sender. NOTICE TO HOMEOWNERS’ ASSOCIATION AND CONDOMINIUM ASSOCIATION CLIENTS: This communication (and any attachments) may include privileged communications between attorney and client that are exempt from disclosure and/or protected pursuant to Sections 90.502, 718.111(12) and/or 720.303(4), Fla. Stat. In such event and to protect the privileged nature of this communication, this communication should not be placed in, or considered to be part of, the official records of an association pursuant to Sections 718.111(12) or 720.303(4), Fla. Stat., as applicable, until such time as the board of directors has determined to make its contents public. If you have an urgent communication or if you have not heard from me in response to your e-mail, please telephone me immediately. DO NOT ASSUME THAT YOUR E-MAIL HAS BEEN RECEIVED. Me ORS NEE ROAR, SARA A ARMMARA LARA UR NR AA SOS te ari mn Ata eSB LAR AALS JON be eo San an ANAS Naan 8 AMMAR AAR SA AANA Ale MRA NRA APA 2 ON A RRR ARRON URINAL UMRAO MA AS a Pay nA mA RAY yy RE NN oh? MLAB ore tener dindnday aarbhRy AAA Annan AAMMAMYE Mb a AAA YY ane RA ARAN dineslia ean NANA A NSN Maine sini: mania Ate AAA ASE en IE wel, From: Alan Borden [mailto: Aborden@1800debtrelief com] Sent: Friday, May 26, 2017 2:01 PM To: Joseph A. Gugino Subject: Firs Lido v. Clo-Ann Garrison 2014-CA-004931-NC | do not represent Mrs. Garrison in the above mentioned case, | wanted to make sure that your office is aware that | should not be a barrier to speaking with the Defendant directly. EXHIBIT A Filed 03/07/2018 12:56 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FLHelpful Tips -> sdiz indy User Name ~ Public Group - Public Anon Internet Home Search Case Lists Logout Subscribe To Email Alerts Return To Search View Printer Friendly Version _ 2014 CA 004931 Uniform Case Case Number: NC Number: 582014CA004931XXXANC Case Status: REOP Case File Date: 08/22/2014 Case Close Date: 03/31/2015 Judge: MCHUGH, ANDREA Party information FIRST LIDO CONDOMINIUM, INC. A FLORIDA NOT-FOR-PROFIT laintif A AN OS /30n018 CORPORATION ainti ( ) GUGINO, JOSEPH (05/16/2017) _GARRISON, CLO ANN Defendant ||BORDEN, ALAN (05/30/2015) "BANK OF AM ERICA NA Defendant HANSON, MARK UNKNOWN TENANT IN POSSESSION, TENANT Defendant ALAN (05/30/2015) UNKNOWN TENANT IN POSSESSION, TENANT “Defendant SECRETARY OF HOUSING AND URBAN DEVELOPMENT Defendant Case Events 02/19/2015 09:45 AM COURTROOM 6C MOTIONS 03/03/2015 01:30 PM COURTROOM 1 MOTIONS eran tee teen serene 05/05/2015 09:00 AM COURTROOM ONLINE | JUDICIAL SALES 03/29/2016 —-—«| 09:00AM ~=—*«| COURTROOMONLINE ——i«™” 07/06/2017 09:00 AM COURTROOM ONLINE | JUDICIAL SALES 10/04/2017 09:00 AM COURTROOM ONLINE JUDICIAL SALES Case Fees JUDICIAL SALES - ELECTRONIC SALE FEE $70.00 $70.00 $0.00 $0.00 SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE | $10.00 | $10. 00 $0.00 $0.00 SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE $10.00 $10.00 $0.00 $0.00 "SUMMONS CIRCUIT EFILED - REQUEST FOR ISSUANCE | $10.00 | $10.00 ooo 8=8F—