On July 20, 2022 a
Party Statement
was filed
involving a dispute between
First Investors Servicing Corp.,
and
Heather Heath,
for COMPLAINT ON CONTRACT OR OTHER DEBT - $5001 - $8000 Division: CC-Q
in the District Court of Duval County.
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Filing # 160502578 E-Filed 11/02/2022 03:44:27 PM
IN THE COUNTY COURT OF THE
FOURTH JUDICIAL CIRCUIT, IN AND
FOR DUVAL COUNTY, FLORIDA
FIRST INVESTORS SERVICING CORP., Case No: 16-2022-SC-015735-
XXXX-MA
PLAINTIFF,
SMALL CLAIMS DIVISION
VS.
HEATHER HEATH
DEFENDANT(S).
AFFIDAVIT OF FAILURE TO PAY SETTLEMENT PAYMENTS
STATE OF FLORIDA
COUNTY OF PALM BEACH
BEFORE ME, the undersigned authority, personally appeared [] Joshua Kaplan, Esq., Fla.
Bar 1019227, L] Timothy Landers, Esq., Fla. Bar 127154, [] Moura Sheron, Esq., Fla. Bar 025992 x]
Vanessa Lambert, Esq., Fla. Bar 693081, who being first duly sworn, deposes and says:
1 Affiant is an attorney employed by Tromberg, Morris & Poulin, PLLC (hereinafter referred
to as, “TMP”), counsel for Plaintiff in the instant action.
Affiant makes this Affidavit of Affiant’s own personal knowledge.
Affiant is competent to testify to the matters stated therein.
TMP maintains payment records for the subject account. As part of my job responsibilities
for TMP, I am familiar with the type of records maintained by TMP in connection with the
subject account.
The information contained in this affidavit is Affiant has personal knowledge of TMP’s
procedures for creating business records. Affiant is in care, custody and control of TMP.'s
business records concerning the account. The records are made at or near the time of the
occurrence of the matters recorded by persons with personal knowledge of the information
in the business record, or from information transmitted by a person with personal
knowledge; kept in the course of TMP’s regularly conducted business activities and it is
the regular practice for TMP’s to make and maintain such records.
FL_AFM-STP
ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 11/04/2022 10:23:06 AM
On 08/26/2022, a settlement agreement was entered into between Defendant(s), Heather
Heath _, and the Plaintiff.
The settlement agreement requires that Defendant(s) to make monthly payments for the
debt to Plaintiff’s Counsel, TMP.
To date, the Defendant(s) has/have failed to make the settlement payment due for
11/19/2022 and all subsequent settlement payments.
Defendant(s) has/have paid a total of $1000.00 as part of the settlement of this matter.
10 In accordance, the Defendant(s) is/are in default of the Settlement Agreement and a total
of $6583.61 is due and owing.
By: (¢(Vanecer Lambut-
(J Joshua Kaplan, Esq., Fla. Bar 1019227
LJ Timothy Landers, Esq., Fla. Bar 127154
LC Moura Sheron, Esq., Fla. Bar 025992
Vanessa Lambert, Esq., Fla. Bar 693081
Attorney for Plaintiff
1515 South Federal Highway, Suite 100
Boca Raton, FL 33432
(800)280-6205 Phone/ 212-227-9656 Fax
E-service Address: pleadings@tmppllc.com
Matter# 466879
FL_AFM-STP
Document Filed Date
November 02, 2022
Case Filing Date
July 20, 2022
Category
COMPLAINT ON CONTRACT OR OTHER DEBT - $5001 - $8000 Division: CC-Q
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Filing # 160502578 E-Filed 11/02/2022 03:44:27 PM IN THE COUNTY COURT OF THE FOURTH JUDICIAL CIRCUIT, IN AND FOR DUVAL COUNTY, FLORIDA FIRST INVESTORS SERVICING CORP., Case No: 16-2022-SC-015735- XXXX-MA PLAINTIFF, SMALL CLAIMS DIVISION VS. HEATHER HEATH DEFENDANT(S). AFFIDAVIT OF FAILURE TO PAY SETTLEMENT PAYMENTS STATE OF FLORIDA COUNTY OF PALM BEACH BEFORE ME, the undersigned authority, personally appeared [] Joshua Kaplan, Esq., Fla. Bar 1019227, L] Timothy Landers, Esq., Fla. Bar 127154, [] Moura Sheron, Esq., Fla. Bar 025992 x] Vanessa Lambert, Esq., Fla. Bar 693081, who being first duly sworn, deposes and says: 1 Affiant is an attorney employed by Tromberg, Morris & Poulin, PLLC (hereinafter referred to as, “TMP”), counsel for Plaintiff in the instant action. Affiant makes this Affidavit of Affiant’s own personal knowledge. Affiant is competent to testify to the matters stated therein. TMP maintains payment records for the subject account. As part of my job responsibilities for TMP, I am familiar with the type of records maintained by TMP in connection with the subject account. The information contained in this affidavit is Affiant has personal knowledge of TMP’s procedures for creating business records. Affiant is in care, custody and control of TMP.'s business records concerning the account. The records are made at or near the time of the occurrence of the matters recorded by persons with personal knowledge of the information in the business record, or from information transmitted by a person with personal knowledge; kept in the course of TMP’s regularly conducted business activities and it is the regular practice for TMP’s to make and maintain such records. FL_AFM-STP ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 11/04/2022 10:23:06 AM On 08/26/2022, a settlement agreement was entered into between Defendant(s), Heather Heath _, and the Plaintiff. The settlement agreement requires that Defendant(s) to make monthly payments for the debt to Plaintiff’s Counsel, TMP. To date, the Defendant(s) has/have failed to make the settlement payment due for 11/19/2022 and all subsequent settlement payments. Defendant(s) has/have paid a total of $1000.00 as part of the settlement of this matter. 10 In accordance, the Defendant(s) is/are in default of the Settlement Agreement and a total of $6583.61 is due and owing. By: (¢(Vanecer Lambut- (J Joshua Kaplan, Esq., Fla. Bar 1019227 LJ Timothy Landers, Esq., Fla. Bar 127154 LC Moura Sheron, Esq., Fla. Bar 025992 Vanessa Lambert, Esq., Fla. Bar 693081 Attorney for Plaintiff 1515 South Federal Highway, Suite 100 Boca Raton, FL 33432 (800)280-6205 Phone/ 212-227-9656 Fax E-service Address: pleadings@tmppllc.com Matter# 466879 FL_AFM-STP