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IN THE CIRCUIT/COUNTY COURT OF THE
NINTH JUDICIAL CIRCUIT, IN AND
FOR ORANGE COUNTY, FLORIDA
22 50th
2022-CC-001473-0
|, Clerk of the Circuit and County Courts in and for Orange County,
Florida do hereby certify that the foregoing pages contain a correct transcript of the record.
IN WITNESS WHEREOF, | have set my hand and affixed the seal of the Circuit Court
in and for Orange County, Florida, on this 7th day of June, 2022.
Tiffany Moore Russell
Clerk of the Circuit and County Courts
425 N. Orange Ave., Orlando, FL 32801
(407) 836-2000
Samantha Pagan
Deputy Clerk
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Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
FORM 1.997. CIVIL COVER SHEET
The civil cover sheet and the information contained in it neither replace nor supplement the filing
and service of pleadings or other documents as required by law. This form must be filed by the
plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant
to section 25.075, Florida Statutes. (See instructions for completion.)
L CASE STYLE
IN THE CIRCUIT/COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT,
IN AND FOR ORANGE COUNTY, FLORIDA
Capital One NA
Plaintiff Case #
Judge
vs.
Priscilla Jordan
Defendant
I. AMOUNT OF CLAIM
Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of
the claim is requested for data collection and clerical processing purposes only. The amount of the claim
shall not be used for any other purpose.
O $8,000 or less
$8,001 - $30,000
OD $30,001- $50,000
DO $50,001- $75,000
0 $75,001 - $100,000
O over $100,000.00
Il. TYPE OF CASE (If the case fits more than one type of case, select the most
definitive category.) If the most descriptive label is a subcategory (is indented under a broader
category), place an x on both the main category and subcategory lines.
-1-
CIRCUIT CIVIL
O Condominium
Q Contracts and indebtedness
O Eminent domain
C Auto negligence
O Negligence—other
C Business governance
C Business torts
© Environmental/Toxic tort
0 Third party indemnification
Q Construction defect
C Mass tort
C Negligent security
C Nursing home negligence
C Premises liability—commercial
C Premises liability—tresidential
O Products liability
C Real Property/Mortgage foreclosure
C Commercial foreclosure
OC Homestead residential foreclosure
C Non-homestead residential foreclosure
CO Other real property actions
Professional
UO malpractice
O Malpractice—business
0 Malpractice—medical.
C Malpractice—other professional
O Other
C Antitrust/Trade regulation
0 Business transactions
O Constitutional challenge—statute or ordinance
O Constitutional challenge—proposed amendment
© Corporate trusts
O Discrimination—employment or other
C Insurance claims
C Intellectual property
0 Libel/Slander
O Shareholder derivative action
O Securities litigation
O Trade secrets
O Trust litigation
COUNTY CIVIL
O Small Claims up to $8,000
& Civil
O Real property/Mortgage foreclosure
-2-
O Replevins
0 Evictions
O Residential Evictions
O Non-residential Evictions
0 Other civil (non-monetary)
COMPLEX BUSINESS COURT
This action is appropriate for assignment to Complex Business Court as delineated and mandated by the
Administrative Order. Yes 0 No
Iv. REMEDIES SOUGHT (check all that apply):
Monetary;
0 Nonmonetary declaratory or injunctive relief;
0 Punitive
Vv. NUMBER OF CAUSES OF ACTION: [ ]
(Specify)
i1
VI. IS THIS CASE A CLASS ACTION LAWSUIT?
O yes
& no
VIL. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?
& no
yes If “yes,” list all related cases by name, case number, and court.
VII. IS JURY TRIAL DEMANDED IN COMPLAINT?
O yes
& no
I CERTIFY that the information I have provided in this cover sheet is accurate to the best of
my knowledge and belief, and that I have read and will comply with the requirements of
Florida Rule of Judicial Administration 2.425.
Signature: s/ RAMIRO KRUSS Fla. Bar# 1011021
Attorney or party ar # if attorney)
RAMIRO KRUSS 01/27/2022
(type or print name) Date
-3-
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT OF THE 9TH
| JUDICIAL CIRCUIT IN AND FOR ORANGE
i COUNTY, FLORIDA
Plaintiff,
CIVIL DIVISION
VS.
| CASE NO:
|
PRISCILLA JORDAN, ||
Defendant.
IPLAINT
Plaintiff, CAPITAL ONE, N.A., sues Defendant, PRISCILLA JORDAN, and alleges:
That this is an action for damages that is within this Court's jurisdictional lirnitations.
Plaintiff is a National Banking Association authorized to do business in Florida.
Defendant, PRISCILLA JORDAN, is an individual, is sui juris, and is a resident of ORANGE County,
Florida.
On November 17, 2015, the Defendant requested an extension of credit from SYNCHRONY BANK
for a CAPITAL ONE WALMART REWARDS CARD.
Plaintiff is the current creditor of the subject credit account.
The credit account number was
All conditions precedent to the bringing of this action have been met or waived.
Plaintiff hereby disclaims any demand or collection of attorney's fees associated with the bringing of
this action.
Defendant caused various charges to be made through the use of said card.
COUNT I (ACCOUNT STATED)
Plaintiff re-alleges all of the allegations set forth in paragraphs 1 - 9.
10. Before the institution of this action, Plaintiff, or Plaintiffs predecessor-in-interest, if any, and
Defendant had business transactions between them and on May 27, 2021, they agreed to the
resulting balance.
1 Plaintiff, or Plaintiff's predecessor-in-interest, if any, rendered a statement of it to Defendant, a copy
being attached hereto, and Defendant did not object to the statement.
12. Defendant(s) owes Plaintiff the principal sum of $9817.02 since May 27, 2021 on the account.
13. Demand for payment has been made.
WHEREFORE, Plaintiff demands judgment for damages of $9817.02 against the Defendant,
PRISCILLA JORDAN, plus costs and disbursements in the institution of this suit, and any other relief
which this Court deems just and proper.
Cc INTI JUST ENRIC!
Plaintiff realleges and reaffirms paragraphs 1-9.
14, The Defendant received a financial benefit, which was in fact appreciated by the Defendant.
15. The Defendant accepted the financial benefit.
16. By virtue of the circumstances surrounding the use of the credit card, the Defendant knowingly
requested the funds in issue and/or knowingly and voluntarily accepted the benefits bestowed.
17. It would be inequitable for this Court to allow the Defendant to retain the benefits or to be unjustly
enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds in issue
without repaying the Plaintiff the value of same.
17. The Plaintiff has no adequate remedy at law if the relief sought is not afforded.
WHEREFORE, Plaintiff demands judgment for damages of $9817.02 against the Defendant,
PRISCILLA JORDAN, plus costs and disbursements in the institution of this suit, and any other
relief which this Court deems just and proper.
lp"
POLLACK & ROSEN, P.A.
KEVIN SPINOZZA, ESQ.
FLA.BAR NO: 90570
Attorneys for the Plaintiff
806 Douglas Road, Suite 200
Coral Gables, Florida 33134
Telephone: (305) 448-0006
Toll Free: (888) 448-1557
Facsimile: (305) 569-0101
E-mail: KEVINS@POLLACKROSEN.COM
LEGALPLEADINGS@POLLACKROSEN.COM
Matter No: 3447069
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Capi fs falOne’ Walmart S¢ Capital One Walmart Rewards® Card | World Mastercard ending in:
Apr 26, 2021 - May 26, 2021 1 31 days in Bilii
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Payment Due Date For online and phone payments, the Previous Balance $9,652.54
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Payments $0.00
New Balance Miniroum Payment Due Other Credits $0.00
$9,817.02 $9,817.02 Transactions + $0.00
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Recoveries department at 1-800-258-9319. Your full balance is due. Any
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Interest Charged + $164.48
New Balance = $9,817.02
Available Credit (as of May 26, 2021) NIA
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Ca i Walmart:
PRISCILLA JORDAN
645 WHITETAIL LOOP
APOPKA, Fl. 32703-3120
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Payment Due Date: Past Due Account ending i
New Balance Minimum Payment Due Amount Enclosed Capital One
$9,817.02 $9,817.02 $ P.O. Box 60519,
City of Industry CA 91716-0819
Please send us this portion of your statement and only one check (or one money orden payable to Capital One Cee ED ee etal ee
to ensure your payment is processed promptly. Allow al feast seven business days for delivery,
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Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT OF THE 9TH
JUDICIAL CIRCUIT IN AND FOR ORANGE
Plaintiff,
COUNTY, FLORIDA
VS.
CIVIL DIVISION
PRISCILLA JORDAN
CASE NO:
Defendant.
——
NON-MILITARY AFFIDAVIT
STATE OF FLORIDA )
COUNTY OF MIAMI-DADE)
nen a —
BEFORE ME, the undersigned authority, personally appeared Stephen Garcia
who, is personally known to me or who produced a valid driver's license as identification, and on
oath, deposes and says:
That the undersigned is associated with POLLACK & ROSEN, P.A., attorneys for Plaintiff herein.
That the Plaintiff submitted an online request for military status to the Defense Manpower Data
Center. The request was based on the social security number search which is confidential
information pursuant to Florida Rule of Judicial Administration 2.420(d)(2).
That in response to said request, Plaintiff received the attached response that the Defendant
PRISCILLA JORDAN, in this action is currently not on Active Military Duty with any of the branches
of the military.
ey for Plaintiff
Non-Military Affidavit was SWORN TO AND SUBSCRIBED before me this day of,
January"®
2022
ws a
lay
State of Florida at Large
My commission expires:
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Matter No: 3447069 oe
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Department of Defense Manpower Data Center eauita os of : Jan-24-2022 06:19:12 AM
SCRA 5.11
Rts
Fa Status Report
a Pursuant to Servicemembers Civil Relief Act
SSN: a
Birth Date:
Last Name: JORDAN
First Name: PRISCILLA
Middle Name:
Status As Of: Jan-24-2022
Certificate ID: SKQZKKZHW28JF8X
Fina ao
Sanaa caine
Active Duty End Date: Status Satis Conner
NA NA No. NA
‘This response reflects the Hidividuats' active duty status tased on the Active Duty Status Date
‘LeflAdive Duly Within 367 Days of Rive Duty Stata Dale
‘ang buy SutDate Active
Duty End Date ‘Status Service Camponent
NA NA, No NA
Tie espe eet whether
ace ya win 067 day preceding
the Acre Buty Sas Date
Tig iissiasar
rier Was eaied Gah cont Ache nay aimee bay Se
‘Oeder Notification Stet Dato Order Notification End Date Status Service Component
NA NA No. NA
‘Thi response reflects whether the inaiwigual hater nl nas ceed article report or ace ty
Upon searching the data banks of the Department
of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/ner unit receiving notification of future orders to report for Active Duty.
Wh Soreril
Michael V. Sorrento, Director
Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
The Defense Manpower Data Genter (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as
the Soldiers’ and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty” responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person
was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked
against you. See 50 USC App. § 3921(c).
This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on “Active Duty Status”
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the
President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the
unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1).
Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service.
Furthermore, some protections of the SCRA may extend to persans who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA
‘extend beyond the fast dates of active duty.
Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA
ate protected
WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing
erroneous information will cause an erroneous certificate to be provided.
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR
ORANGE COUNTY, FLORIDA
Plaintiff,
CIVIL DIVISION
vs.
CASE NO:
PRISCILLA JORDAN,
Defendant.
/
NOTICE OF CONFIDENTIAL INFORMATION WITHIN COURT FILING
COMES NOW, CAPITAL ONE, N.A., Plaintiff in this cause, and notifies the Court and
all interested parties of the filing of Confidential Information in the Court File.
Pursuant to Florida Rule of Judicial Administration 2.420(d)(2), | hereby certify:
lam filing herewith a document containing confidential information as described in Rule
2.420(d)(1)(B)(iii) and that:
The title/type of document is Plaintiffs Complaint/Statement of Claim and:
The confidential information within the document is precisely located at: the Social
Security bank account, charge, debit, and credit card numbers located within the billing
statement attached as an exhibit to Plaintiff's Complaint/Statement of Claim.
POLLACK & ROSEN, P.A.
806 DOUGLAS ROAD
SOUTH TOWER, SUITE 200
CORAL GABLES, FLORIDA 33134
TELEPHONE NO: (305) 448-0006
FACSIMILE: (305) 569-0101
FOR
KEVIN INOZZA, ESQ.
FLA. BAR NO: 90570
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR
ORANGE COUNTY, FLORIDA
Plaintiff,
CIVIL DIVISION
vs.
CASE NO:
PRISCILLA JORDAN,
Defendant(s).
NOTICE OF DESIGNATION OF E-MAIL ADDRESSES
COMES NOW, the undersigned, POLLACK & ROSEN, PA., hereby gives notice,
pursuant to Florida Rule of Judicial Administration 2.516, of the designation of the following e
mail addresses for service by electronic mail: LegalPleadings@PollackRosen.com .
POLLACK & ROSEN, P.A.
806 DOUGLAS ROAD
SOUTH TOWER, SUITE 200
CORAL GABLES, FLORIDA 33134
TELEPHONE NO: (305) 448-0006
FACSIMILE: (305) 569-0101
FoR
KEVIN SPiNOZZA, ESQ.
FLA. BAR NO: 90570
MATTER NO: 3447069
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR
ORANGE COUNTY, FLORIDA
Plaintiff,
CIVIL DIVISION
vs.
CASE NO:
PRISCILLA JORDAN,
Defendant.
CIVIL ACTION SUMMONS
PERSONAL SERVICE ON AN
INDIVIDUAL
IMPORTANTE
EN ESPANOL AL DORSO
IMPORTANT
FRANCAIS AU VERSO
TO:
PRISCILLA JORDAN
645 WHITETAIL LOOP
APOPKA, FL 32703-3120
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is served
on you to file a written response to the attached Complaint in this Court. A phone call will not
protect you; your written response, including the above case number and named parties, must
be filed if you want the Court to hear your case. If you do not file your response on time, you
may lose the case, and your wages, money, and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an attorney,
you may call an attorney referral service or a legal aid office (listed in the phone book).
lf you choose to file a written response yourself, at the same time you file your written
response to the Court located at:
CLERK OF THE COURT
ORANGE COUNTY COURTHOUSE
425 N. ORANGE AVE.
ORLANDO, FL 32801
you must also mail or take a carbon copy or photocopy of your written response to the "Plaintiff's
Attorney” named below:
KEVIN SPINOZZA, ESQ.
POLLACK & ROSEN, P.A.
806 DOUGLAS ROAD
SOUTH TOWER-SUITE 200
CORAL GABLES, FLORIDA 33134
TELEPHONE NO: 305-448-0006
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons, a copy of
the Complaint in this lawsuit on the above-named Defendant.
DATED ON » 2022. Clerk of the Circuit Court
(Court Seal) By
Deputy Clerk
MATTER NO: 3447069
IMPORTANTE
Usted ha sido demandado legalmente. Tiene veinte (20) dias, contados a partir del recibo
de esta nificacién, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal.
Una llamada telefénica no lo protegera; si usted desea que el triounal considere su defensa, debe
presentar su respuesta por escrito, incluyendo el namero del caso y los nombres de las partes
interesadas en dicho caso. Si usted no contesta la demanda a tiempo, pudiese perder el caso y
podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso
del tribunal. Existen otros requisitos legales. Si lo desea, puede usted consultar a un abogado
immediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia
legal que aparecen en la guia telefénica.
Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su
respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a
la persona denominada abajo como "Plaintiff/Plaintiffs Attorney". (Demandante o Abogado del
Demandante).
IMPORTANT
Des poursuites judiciaries ont été entreprises contre vous. Vous avez 20 jours consecutifs
a partir de la date de l'assignation de cet citation pour deposer une response écrite a la plainte ci-
jointe auprés de ce Tribunal. Un simple coup de téléphone est insuffisant pour vous protegér; vous
&tes obligé de déposer votre réponse écrite, avec mention du numéro de dossier ci-dessus et do
nom des parties nommées ici, si vous souhaitez que le Tribunal entende votre cause. Si vous ne
déposez pas votre reponse écrite dans le relai requis, vous risquez de perdre la cause ainsi que
votre salaire, votre argent, et vos biens peuvent étre saisis par la suite, sans aucun préavis ulterieur
du Tribunal. Il y a d'autres obligations juridiques et vous pouvez réquerir les services immediats
d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez téléphoner a un service de référence
d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de téléphones).
Si vous choisissez de déposer vous-méme une résponse écrite, il vous faudra également,
en méme temps que cette formalité, faire parvenir ou expédier une copie au carbone ou une
photocopie de votre réponse ecrite au "Plaintiff/Plaintiffis Attorney" (Plaignant ou a son avocat)
nommé ci-dessous.
EXPLANATION
The summons form for personal service on individuals is to be used for service on individuals
under the following provisions: Florida Statutes 48.031 (service of process generally), 48.041
(service on minors), 48.042 (service on incompetents), 48.051 (service on state prisoners, 48.103
(service of process in action for possession of residential premises), and 48.194 (personal service
outside the state). on state prisoners, 48.103 (service of process in action for possession of
residential premises), and 48.194 (personal service outside the state).
MATTER NO: 3447065
Americans with Disabilities Act of 1990, 42 U.S.C. § 12101, et seq.
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision
of certain assistance. Please contact Court Administration at_ 425 N. Orange
Avenue, Room 2130, Orlando, Florida 32801, Telephone: (407) 836-2303 within
two (2) working days of your receipt of this (describe notice); If you are hearing
r voice impaired, call 1-800-955-8771.
MATTER NO: 3447069
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
IN THE COUNTY/CIRCUIT COURT OF
THE NINTH JUDICIAL CIRCUIT, IN
AND FOR ORANGE AND OSCEOLA
COUNTY, FLORIDA
IN RE: CIVIL CASE MANAGEMENT
PLAN AND ORDER
STANDING CASE MANAGEMENT PLAN/ORDER (General Track)
PURSUANT TO /n re: Comprehensive COVID-19 Emergency Measures for
Florida Trial Courts, Fla. Admin. Order No. AOSC20-23 (Amendment 12) (April 13,
2021), and Ninth Judicial Circuit Court Administrative Order No. 2021-04 (collectively the “Case
Management Administrative Orders”), this case is before the Court for case management. Based
on the case type of the initial filing in this case, the Case Management Administrative Orders, and
pursuant to Rule 2.545, Fla. R. Gen. Prac. &
Jud. Admin., the Court hereby establishes a case management plan. It is hereby
ORDERED that:
1. COMPLIANCE WITH THIS CASE MANAGEMENT PLAN/ORDER: The
parties shall strictly comply with the terms of this Case Management Plan/Order, unless otherwise
ordered by the Court. FAILURE TO COMPLY WITH ALL REQUIREMENTS OF THIS ORDER
WILL RESULT IN THE IMPOSITION OF SANCTIONS. If the parties believe that an alternate
plan is required or more appropriate, then the parties shall meet, confer and agree on a plan that
complies with the time standards set forth in Rule 2.250, Fla. R. Gen. Prac. & Jud. Admin. The
parties may submit an agreed upon plan to the division judge for consideration, or set the matter for
a case management conference.
2. ADDITIONAL NINTH CIRCUIT AND DIVISION SPECIFIC GUIDELINES:
All counsel and unrepresented parties shall familiarize themselves and comply with the
requirements of the following: (i) Amended Administrative Order Establishing the Ninth
Judicial Circuit Court Circuit Civil Court Guidelines (AO 2012-03-01 (ii)
Amended Administrative Order Establishing the Ninth Judicial Circuit Courtroom
Decorum Policy (AO 2003-07-02) (iii) Amended Administrative Order Establishing
the Ninth Judicial Circuit Court County Civil Court Guidelines, Orange County
(A02017-04-01) and (iv) any division-specific quidelines that may be applicable.
3. MODIFICATION OF THIS ORDER: The parties may not, individually or by agreement,
alter or extend the deadlines in this Order, or waive any of the provisions of this Order. The
provisions of this Order may be modified only upon motion/stipulation and Court order in
accordance with applicable law.
4. SERVICE OF THIS ORDER WITH INITIAL PROCESS: Pursuant to the
Case Management Orders, the Plaintiff shall file a copy of this Order in the case. Any party
serving an initial pleading (complaint, third-party complaint, etc.) in this case shall serve a copy of
this Order together with initial service of process.
CASE MANAGEMENT PLAN — GENERAL TRACK
Note: All dates are to be calculated from the date of filing of the initial complaint unless
otherwise noted.
Deadline for Service of Process: 120 days
Deadline for Service of Process extended if 150 days, failing same, all unserved
not accomplished within 120 days: defendants are dismissed without
prejudice
Deadline for Leave to Add Parties and Amend Motions must be set for hearing and heard
Pleadings: within 90 days from service on the
last defendant, or deemed abandoned
and denied
Motions to Dismiss, Motions for More Must be set for hearing and heard within
Definite Statement, Motions to Strike and any 60 days from filing of the motion/objection,
objections to the pleadings: or deemed abandoned and denied. Non-
movant shall timely
submit a proposed order in the event the
motion/objection is deemed abandoned
and denied
Deadline for Completion of Fact and Expert 450 days
Discovery: (additional disclosure and discovery deadlines
will be established by the
Uniform Order Setting Pre-Trial and Trial in
the case)
Pre-trial Motions, including Dispositive and Must be filed no later than 15 days after
Daubert Motions completion of discovery and heard no later
than 7 days prior to the pre-trial conference, or
deemed abandoned and
denied
Mediation/Alternative Dispute Resolution Within 30 days after completion of the
depositions of all parties, counsel shall meet
and confer regarding whether an
early mediation would be productive to
resolution of certain issues or the entire case.
A final mediation shall occur no later than 30
days after completion of all
discovery
Approximate Pre-Trial Conference: 17 months
Actual Date to be set by Trial Order
Approximate Trial Date: 18 months
Actual date to be set by Trial Order
5. NOTICES FOR TRIAL: Within ten (10) days of the case being at issue as defined by
Rule 1.440, Fla. R. Civ. P., the Plaintiff shall confer with opposing counsel/party regarding the
anticipated length of trial and file a Notice for Trial. The Plaintiff shall forward a copy of the
Notice for Trial to the Judicial Assistant at the Division email address noted on the Ninth
Circuit website.
6. DISCOVERY: All counsel and unrepresented parties shall familiarize themselves with the
current edition of the Florida Handbook on Civil Discovery Practice and seek to resolve
discovery issues without court intervention whenever possible.
7. SETTLEMENT: The case will not be removed from the docket until all documents
necessary for closure of the case are filed with the Clerk and notification has been
provided to the judicial assistant. A notice of settlement is not sufficient to remove the
case from the trial docket.
DONE AND ORDERED in Orange/Osceola County, Florida.
|.
Chief Judge
If you are a person with a disability who needs any accommodation in
order to participate in this proceeding, you are entitled, at no cost to you,
to the provision of certain assistance. Please contact the ADA
Coordinator in your county at least 7 days before your scheduled court
appearance, or immediately upon receiving this notification if the time
before the scheduled appearance is less than 7 days. If you are hearing
or voice impaired, call 711.
ORANGE COUNTY: Human Resources, Orange County Courthouse, 425
N. Orange Avenue, Suite 510, Orlando, Florida, (407) 836-2303
OSCEOLA COUNTY: Court Administration, Osceola County
Courthouse, 2 Courthouse Square, Suite 6300, Kissimmee, Florida, (407)
742-2417
REV 04/29/2021
MATTER NO: 3447069
Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM
CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR
ORANGE COUNTY, FLORIDA
Plaintiff,
CIVIL DIVISION
vs.
CASE NO: 2022-cc-001473-0
PRISCILLA JORDAN,
Defendant.
/
CIVIL ACTION SUMMONS
PERSONAL SERVICE ON AN
INDIVIDUAL
IMPORTANTE
EN ESPANOL AL DORSO
IMPORTANT
FRANCAIS AU VERSO
TO:
PRISCILLA JORDAN
645 WHITETAIL LOOP
APOPKA, FL 32703-3120
IMPORTANT
A lawsuit has been filed against you. You have 20 calendar days after this summons is served
on you to file a written response to the attached Complaint in this Court. A phone call will not
protect you; your written response, including the above case number and named parties, must
be filed if you want the Court to hear your case. If you do not file your response on time, you
may lose the case, and your wages, money, and property may thereafter be taken without further
warning from the Court. There are other legal requirements. You may want to call an attorney,
you may call an attorney referral service or a legal aid office (listed in the phone book).
If you choose to file a written response yourself, at the same time you file your written
response to the Court located at:
CLERK OF THE COURT
ORANGE COUNTY COURTHOUSE
425 N. ORANGE AVE.
ORLANDO, FL 32801
you must also mail or take a carbon copy or photocopy of your written response to the "Plaintiff's
Attorney" named below:
KEVIN SPINOZZA, ESQ.
POLLACK & ROSEN, P.A.
806 DOUGLAS ROAD
SOUTH TOWER-SUITE 200
CORAL GABLES, FLORIDA 33134
TELEPHONE NO: 305-448-0006
THE STATE OF FLORIDA
TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons, a copy of
the Complaint in this lawsuit on the above-named Defendant.
Tiffany Moore Russell
DATED ON 01.31 , 2022, Clerk of the Circuit Court
Le
£5;tS)
(Court Seal) be 3] By
/of Grace Katherine Uy
Se Deputy Clerk
SOON
Givil Division
425 N. Orange Avenue
Room 350
Orlandol, Florida 32801
MATTER
Preview
IN THE CIRCUIT/COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA 22 50th 2022-CC-001473-0 |, Clerk of the Circuit and County Courts in and for Orange County, Florida do hereby certify that the foregoing pages contain a correct transcript of the record. IN WITNESS WHEREOF, | have set my hand and affixed the seal of the Circuit Court in and for Orange County, Florida, on this 7th day of June, 2022. Tiffany Moore Russell Clerk of the Circuit and County Courts 425 N. Orange Ave., Orlando, FL 32801 (407) 836-2000 Samantha Pagan Deputy Clerk ) 4 B53 oF oo Oz aS oO cea Po Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM FORM 1.997. CIVIL COVER SHEET The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant to section 25.075, Florida Statutes. (See instructions for completion.) L CASE STYLE IN THE CIRCUIT/COUNTY COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA Capital One NA Plaintiff Case # Judge vs. Priscilla Jordan Defendant I. AMOUNT OF CLAIM Please indicate the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of the claim is requested for data collection and clerical processing purposes only. The amount of the claim shall not be used for any other purpose. O $8,000 or less $8,001 - $30,000 OD $30,001- $50,000 DO $50,001- $75,000 0 $75,001 - $100,000 O over $100,000.00 Il. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the most descriptive label is a subcategory (is indented under a broader category), place an x on both the main category and subcategory lines. -1- CIRCUIT CIVIL O Condominium Q Contracts and indebtedness O Eminent domain C Auto negligence O Negligence—other C Business governance C Business torts © Environmental/Toxic tort 0 Third party indemnification Q Construction defect C Mass tort C Negligent security C Nursing home negligence C Premises liability—commercial C Premises liability—tresidential O Products liability C Real Property/Mortgage foreclosure C Commercial foreclosure OC Homestead residential foreclosure C Non-homestead residential foreclosure CO Other real property actions Professional UO malpractice O Malpractice—business 0 Malpractice—medical. C Malpractice—other professional O Other C Antitrust/Trade regulation 0 Business transactions O Constitutional challenge—statute or ordinance O Constitutional challenge—proposed amendment © Corporate trusts O Discrimination—employment or other C Insurance claims C Intellectual property 0 Libel/Slander O Shareholder derivative action O Securities litigation O Trade secrets O Trust litigation COUNTY CIVIL O Small Claims up to $8,000 & Civil O Real property/Mortgage foreclosure -2- O Replevins 0 Evictions O Residential Evictions O Non-residential Evictions 0 Other civil (non-monetary) COMPLEX BUSINESS COURT This action is appropriate for assignment to Complex Business Court as delineated and mandated by the Administrative Order. Yes 0 No Iv. REMEDIES SOUGHT (check all that apply): Monetary; 0 Nonmonetary declaratory or injunctive relief; 0 Punitive Vv. NUMBER OF CAUSES OF ACTION: [ ] (Specify) i1 VI. IS THIS CASE A CLASS ACTION LAWSUIT? O yes & no VIL. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? & no yes If “yes,” list all related cases by name, case number, and court. VII. IS JURY TRIAL DEMANDED IN COMPLAINT? O yes & no I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. Signature: s/ RAMIRO KRUSS Fla. Bar# 1011021 Attorney or party ar # if attorney) RAMIRO KRUSS 01/27/2022 (type or print name) Date -3- Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT OF THE 9TH | JUDICIAL CIRCUIT IN AND FOR ORANGE i COUNTY, FLORIDA Plaintiff, CIVIL DIVISION VS. | CASE NO: | PRISCILLA JORDAN, || Defendant. IPLAINT Plaintiff, CAPITAL ONE, N.A., sues Defendant, PRISCILLA JORDAN, and alleges: That this is an action for damages that is within this Court's jurisdictional lirnitations. Plaintiff is a National Banking Association authorized to do business in Florida. Defendant, PRISCILLA JORDAN, is an individual, is sui juris, and is a resident of ORANGE County, Florida. On November 17, 2015, the Defendant requested an extension of credit from SYNCHRONY BANK for a CAPITAL ONE WALMART REWARDS CARD. Plaintiff is the current creditor of the subject credit account. The credit account number was All conditions precedent to the bringing of this action have been met or waived. Plaintiff hereby disclaims any demand or collection of attorney's fees associated with the bringing of this action. Defendant caused various charges to be made through the use of said card. COUNT I (ACCOUNT STATED) Plaintiff re-alleges all of the allegations set forth in paragraphs 1 - 9. 10. Before the institution of this action, Plaintiff, or Plaintiffs predecessor-in-interest, if any, and Defendant had business transactions between them and on May 27, 2021, they agreed to the resulting balance. 1 Plaintiff, or Plaintiff's predecessor-in-interest, if any, rendered a statement of it to Defendant, a copy being attached hereto, and Defendant did not object to the statement. 12. Defendant(s) owes Plaintiff the principal sum of $9817.02 since May 27, 2021 on the account. 13. Demand for payment has been made. WHEREFORE, Plaintiff demands judgment for damages of $9817.02 against the Defendant, PRISCILLA JORDAN, plus costs and disbursements in the institution of this suit, and any other relief which this Court deems just and proper. Cc INTI JUST ENRIC! Plaintiff realleges and reaffirms paragraphs 1-9. 14, The Defendant received a financial benefit, which was in fact appreciated by the Defendant. 15. The Defendant accepted the financial benefit. 16. By virtue of the circumstances surrounding the use of the credit card, the Defendant knowingly requested the funds in issue and/or knowingly and voluntarily accepted the benefits bestowed. 17. It would be inequitable for this Court to allow the Defendant to retain the benefits or to be unjustly enriched at the expense of the Plaintiff or allow the Defendant to retain the value of the funds in issue without repaying the Plaintiff the value of same. 17. The Plaintiff has no adequate remedy at law if the relief sought is not afforded. WHEREFORE, Plaintiff demands judgment for damages of $9817.02 against the Defendant, PRISCILLA JORDAN, plus costs and disbursements in the institution of this suit, and any other relief which this Court deems just and proper. lp" POLLACK & ROSEN, P.A. KEVIN SPINOZZA, ESQ. FLA.BAR NO: 90570 Attorneys for the Plaintiff 806 Douglas Road, Suite 200 Coral Gables, Florida 33134 Telephone: (305) 448-0006 Toll Free: (888) 448-1557 Facsimile: (305) 569-0101 E-mail: KEVINS@POLLACKROSEN.COM LEGALPLEADINGS@POLLACKROSEN.COM Matter No: 3447069 ———p o Pa Capi fs falOne’ Walmart S¢ Capital One Walmart Rewards® Card | World Mastercard ending in: Apr 26, 2021 - May 26, 2021 1 31 days in Bilii een Poon penn eee Payment Due Date For online and phone payments, the Previous Balance $9,652.54 PAST DUE deadiine is 8pm ET. Payments $0.00 New Balance Miniroum Payment Due Other Credits $0.00 $9,817.02 $9,817.02 Transactions + $0.00 IMPORTANT: Your account has charged off and is naw serviced by the Quick Cash + $0.00 Recoveries department at 1-800-258-9319. Your full balance is due. Any payment you make will reduce your balance and help pay off your debt Cash Advances + $0.00 | faster. The amount you owe may differ if you've entered into a separate [_ payment agreement. . Fees Charged + $0.00 Interest Charged + $164.48 New Balance = $9,817.02 Available Credit (as of May 26, 2021) NIA Account Notifications @ Welcome to your account natifications. Check back here each month for important updates about your account, Payor manage your account at Walrnast.capitalone.com Customer Service: 1-877-860-1250 See reverse for tmportant Information - D8 Ca i Walmart: PRISCILLA JORDAN 645 WHITETAIL LOOP APOPKA, Fl. 32703-3120 Mfefey!UetOfO ef yalgontegg flog tN UO Uf ed tp teyffaaty Payment Due Date: Past Due Account ending i New Balance Minimum Payment Due Amount Enclosed Capital One $9,817.02 $9,817.02 $ P.O. Box 60519, City of Industry CA 91716-0819 Please send us this portion of your statement and only one check (or one money orden payable to Capital One Cee ED ee etal ee to ensure your payment is processed promptly. Allow al feast seven business days for delivery, ae Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT OF THE 9TH JUDICIAL CIRCUIT IN AND FOR ORANGE Plaintiff, COUNTY, FLORIDA VS. CIVIL DIVISION PRISCILLA JORDAN CASE NO: Defendant. —— NON-MILITARY AFFIDAVIT STATE OF FLORIDA ) COUNTY OF MIAMI-DADE) nen a — BEFORE ME, the undersigned authority, personally appeared Stephen Garcia who, is personally known to me or who produced a valid driver's license as identification, and on oath, deposes and says: That the undersigned is associated with POLLACK & ROSEN, P.A., attorneys for Plaintiff herein. That the Plaintiff submitted an online request for military status to the Defense Manpower Data Center. The request was based on the social security number search which is confidential information pursuant to Florida Rule of Judicial Administration 2.420(d)(2). That in response to said request, Plaintiff received the attached response that the Defendant PRISCILLA JORDAN, in this action is currently not on Active Military Duty with any of the branches of the military. ey for Plaintiff Non-Military Affidavit was SWORN TO AND SUBSCRIBED before me this day of, January"® 2022 ws a lay State of Florida at Large My commission expires: Lo Matter No: 3447069 oe eects Songea8%, 4% %, Pani uct ee aay Department of Defense Manpower Data Center eauita os of : Jan-24-2022 06:19:12 AM SCRA 5.11 Rts Fa Status Report a Pursuant to Servicemembers Civil Relief Act SSN: a Birth Date: Last Name: JORDAN First Name: PRISCILLA Middle Name: Status As Of: Jan-24-2022 Certificate ID: SKQZKKZHW28JF8X Fina ao Sanaa caine Active Duty End Date: Status Satis Conner NA NA No. NA ‘This response reflects the Hidividuats' active duty status tased on the Active Duty Status Date ‘LeflAdive Duly Within 367 Days of Rive Duty Stata Dale ‘ang buy SutDate Active Duty End Date ‘Status Service Camponent NA NA, No NA Tie espe eet whether ace ya win 067 day preceding the Acre Buty Sas Date Tig iissiasar rier Was eaied Gah cont Ache nay aimee bay Se ‘Oeder Notification Stet Dato Order Notification End Date Status Service Component NA NA No. NA ‘Thi response reflects whether the inaiwigual hater nl nas ceed article report or ace ty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/ner unit receiving notification of future orders to report for Active Duty. Wh Soreril Michael V. Sorrento, Director Department of Defense - Manpower Data Center 400 Gigling Rd. Seaside, CA 93955 The Defense Manpower Data Genter (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as the Soldiers’ and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty” responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 3921(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on “Active Duty Status” Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persans who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA ‘extend beyond the fast dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA ate protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR ORANGE COUNTY, FLORIDA Plaintiff, CIVIL DIVISION vs. CASE NO: PRISCILLA JORDAN, Defendant. / NOTICE OF CONFIDENTIAL INFORMATION WITHIN COURT FILING COMES NOW, CAPITAL ONE, N.A., Plaintiff in this cause, and notifies the Court and all interested parties of the filing of Confidential Information in the Court File. Pursuant to Florida Rule of Judicial Administration 2.420(d)(2), | hereby certify: lam filing herewith a document containing confidential information as described in Rule 2.420(d)(1)(B)(iii) and that: The title/type of document is Plaintiffs Complaint/Statement of Claim and: The confidential information within the document is precisely located at: the Social Security bank account, charge, debit, and credit card numbers located within the billing statement attached as an exhibit to Plaintiff's Complaint/Statement of Claim. POLLACK & ROSEN, P.A. 806 DOUGLAS ROAD SOUTH TOWER, SUITE 200 CORAL GABLES, FLORIDA 33134 TELEPHONE NO: (305) 448-0006 FACSIMILE: (305) 569-0101 FOR KEVIN INOZZA, ESQ. FLA. BAR NO: 90570 Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR ORANGE COUNTY, FLORIDA Plaintiff, CIVIL DIVISION vs. CASE NO: PRISCILLA JORDAN, Defendant(s). NOTICE OF DESIGNATION OF E-MAIL ADDRESSES COMES NOW, the undersigned, POLLACK & ROSEN, PA., hereby gives notice, pursuant to Florida Rule of Judicial Administration 2.516, of the designation of the following e mail addresses for service by electronic mail: LegalPleadings@PollackRosen.com . POLLACK & ROSEN, P.A. 806 DOUGLAS ROAD SOUTH TOWER, SUITE 200 CORAL GABLES, FLORIDA 33134 TELEPHONE NO: (305) 448-0006 FACSIMILE: (305) 569-0101 FoR KEVIN SPiNOZZA, ESQ. FLA. BAR NO: 90570 MATTER NO: 3447069 Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR ORANGE COUNTY, FLORIDA Plaintiff, CIVIL DIVISION vs. CASE NO: PRISCILLA JORDAN, Defendant. CIVIL ACTION SUMMONS PERSONAL SERVICE ON AN INDIVIDUAL IMPORTANTE EN ESPANOL AL DORSO IMPORTANT FRANCAIS AU VERSO TO: PRISCILLA JORDAN 645 WHITETAIL LOOP APOPKA, FL 32703-3120 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached Complaint in this Court. A phone call will not protect you; your written response, including the above case number and named parties, must be filed if you want the Court to hear your case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). lf you choose to file a written response yourself, at the same time you file your written response to the Court located at: CLERK OF THE COURT ORANGE COUNTY COURTHOUSE 425 N. ORANGE AVE. ORLANDO, FL 32801 you must also mail or take a carbon copy or photocopy of your written response to the "Plaintiff's Attorney” named below: KEVIN SPINOZZA, ESQ. POLLACK & ROSEN, P.A. 806 DOUGLAS ROAD SOUTH TOWER-SUITE 200 CORAL GABLES, FLORIDA 33134 TELEPHONE NO: 305-448-0006 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons, a copy of the Complaint in this lawsuit on the above-named Defendant. DATED ON » 2022. Clerk of the Circuit Court (Court Seal) By Deputy Clerk MATTER NO: 3447069 IMPORTANTE Usted ha sido demandado legalmente. Tiene veinte (20) dias, contados a partir del recibo de esta nificacién, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada telefénica no lo protegera; si usted desea que el triounal considere su defensa, debe presentar su respuesta por escrito, incluyendo el namero del caso y los nombres de las partes interesadas en dicho caso. Si usted no contesta la demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted consultar a un abogado immediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de asistencia legal que aparecen en la guia telefénica. Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la persona denominada abajo como "Plaintiff/Plaintiffs Attorney". (Demandante o Abogado del Demandante). IMPORTANT Des poursuites judiciaries ont été entreprises contre vous. Vous avez 20 jours consecutifs a partir de la date de l'assignation de cet citation pour deposer une response écrite a la plainte ci- jointe auprés de ce Tribunal. Un simple coup de téléphone est insuffisant pour vous protegér; vous &tes obligé de déposer votre réponse écrite, avec mention du numéro de dossier ci-dessus et do nom des parties nommées ici, si vous souhaitez que le Tribunal entende votre cause. Si vous ne déposez pas votre reponse écrite dans le relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent étre saisis par la suite, sans aucun préavis ulterieur du Tribunal. Il y a d'autres obligations juridiques et vous pouvez réquerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez téléphoner a un service de référence d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de téléphones). Si vous choisissez de déposer vous-méme une résponse écrite, il vous faudra également, en méme temps que cette formalité, faire parvenir ou expédier une copie au carbone ou une photocopie de votre réponse ecrite au "Plaintiff/Plaintiffis Attorney" (Plaignant ou a son avocat) nommé ci-dessous. EXPLANATION The summons form for personal service on individuals is to be used for service on individuals under the following provisions: Florida Statutes 48.031 (service of process generally), 48.041 (service on minors), 48.042 (service on incompetents), 48.051 (service on state prisoners, 48.103 (service of process in action for possession of residential premises), and 48.194 (personal service outside the state). on state prisoners, 48.103 (service of process in action for possession of residential premises), and 48.194 (personal service outside the state). MATTER NO: 3447065 Americans with Disabilities Act of 1990, 42 U.S.C. § 12101, et seq. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Court Administration at_ 425 N. Orange Avenue, Room 2130, Orlando, Florida 32801, Telephone: (407) 836-2303 within two (2) working days of your receipt of this (describe notice); If you are hearing r voice impaired, call 1-800-955-8771. MATTER NO: 3447069 Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM IN THE COUNTY/CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE AND OSCEOLA COUNTY, FLORIDA IN RE: CIVIL CASE MANAGEMENT PLAN AND ORDER STANDING CASE MANAGEMENT PLAN/ORDER (General Track) PURSUANT TO /n re: Comprehensive COVID-19 Emergency Measures for Florida Trial Courts, Fla. Admin. Order No. AOSC20-23 (Amendment 12) (April 13, 2021), and Ninth Judicial Circuit Court Administrative Order No. 2021-04 (collectively the “Case Management Administrative Orders”), this case is before the Court for case management. Based on the case type of the initial filing in this case, the Case Management Administrative Orders, and pursuant to Rule 2.545, Fla. R. Gen. Prac. & Jud. Admin., the Court hereby establishes a case management plan. It is hereby ORDERED that: 1. COMPLIANCE WITH THIS CASE MANAGEMENT PLAN/ORDER: The parties shall strictly comply with the terms of this Case Management Plan/Order, unless otherwise ordered by the Court. FAILURE TO COMPLY WITH ALL REQUIREMENTS OF THIS ORDER WILL RESULT IN THE IMPOSITION OF SANCTIONS. If the parties believe that an alternate plan is required or more appropriate, then the parties shall meet, confer and agree on a plan that complies with the time standards set forth in Rule 2.250, Fla. R. Gen. Prac. & Jud. Admin. The parties may submit an agreed upon plan to the division judge for consideration, or set the matter for a case management conference. 2. ADDITIONAL NINTH CIRCUIT AND DIVISION SPECIFIC GUIDELINES: All counsel and unrepresented parties shall familiarize themselves and comply with the requirements of the following: (i) Amended Administrative Order Establishing the Ninth Judicial Circuit Court Circuit Civil Court Guidelines (AO 2012-03-01 (ii) Amended Administrative Order Establishing the Ninth Judicial Circuit Courtroom Decorum Policy (AO 2003-07-02) (iii) Amended Administrative Order Establishing the Ninth Judicial Circuit Court County Civil Court Guidelines, Orange County (A02017-04-01) and (iv) any division-specific quidelines that may be applicable. 3. MODIFICATION OF THIS ORDER: The parties may not, individually or by agreement, alter or extend the deadlines in this Order, or waive any of the provisions of this Order. The provisions of this Order may be modified only upon motion/stipulation and Court order in accordance with applicable law. 4. SERVICE OF THIS ORDER WITH INITIAL PROCESS: Pursuant to the Case Management Orders, the Plaintiff shall file a copy of this Order in the case. Any party serving an initial pleading (complaint, third-party complaint, etc.) in this case shall serve a copy of this Order together with initial service of process. CASE MANAGEMENT PLAN — GENERAL TRACK Note: All dates are to be calculated from the date of filing of the initial complaint unless otherwise noted. Deadline for Service of Process: 120 days Deadline for Service of Process extended if 150 days, failing same, all unserved not accomplished within 120 days: defendants are dismissed without prejudice Deadline for Leave to Add Parties and Amend Motions must be set for hearing and heard Pleadings: within 90 days from service on the last defendant, or deemed abandoned and denied Motions to Dismiss, Motions for More Must be set for hearing and heard within Definite Statement, Motions to Strike and any 60 days from filing of the motion/objection, objections to the pleadings: or deemed abandoned and denied. Non- movant shall timely submit a proposed order in the event the motion/objection is deemed abandoned and denied Deadline for Completion of Fact and Expert 450 days Discovery: (additional disclosure and discovery deadlines will be established by the Uniform Order Setting Pre-Trial and Trial in the case) Pre-trial Motions, including Dispositive and Must be filed no later than 15 days after Daubert Motions completion of discovery and heard no later than 7 days prior to the pre-trial conference, or deemed abandoned and denied Mediation/Alternative Dispute Resolution Within 30 days after completion of the depositions of all parties, counsel shall meet and confer regarding whether an early mediation would be productive to resolution of certain issues or the entire case. A final mediation shall occur no later than 30 days after completion of all discovery Approximate Pre-Trial Conference: 17 months Actual Date to be set by Trial Order Approximate Trial Date: 18 months Actual date to be set by Trial Order 5. NOTICES FOR TRIAL: Within ten (10) days of the case being at issue as defined by Rule 1.440, Fla. R. Civ. P., the Plaintiff shall confer with opposing counsel/party regarding the anticipated length of trial and file a Notice for Trial. The Plaintiff shall forward a copy of the Notice for Trial to the Judicial Assistant at the Division email address noted on the Ninth Circuit website. 6. DISCOVERY: All counsel and unrepresented parties shall familiarize themselves with the current edition of the Florida Handbook on Civil Discovery Practice and seek to resolve discovery issues without court intervention whenever possible. 7. SETTLEMENT: The case will not be removed from the docket until all documents necessary for closure of the case are filed with the Clerk and notification has been provided to the judicial assistant. A notice of settlement is not sufficient to remove the case from the trial docket. DONE AND ORDERED in Orange/Osceola County, Florida. |. Chief Judge If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in your county at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days. If you are hearing or voice impaired, call 711. ORANGE COUNTY: Human Resources, Orange County Courthouse, 425 N. Orange Avenue, Suite 510, Orlando, Florida, (407) 836-2303 OSCEOLA COUNTY: Court Administration, Osceola County Courthouse, 2 Courthouse Square, Suite 6300, Kissimmee, Florida, (407) 742-2417 REV 04/29/2021 MATTER NO: 3447069 Filing # 142768335 E-Filed 01/27/2022 11:42:50 AM CAPITAL ONE, N.A., IN THE COUNTY COURT IN AND FOR ORANGE COUNTY, FLORIDA Plaintiff, CIVIL DIVISION vs. CASE NO: 2022-cc-001473-0 PRISCILLA JORDAN, Defendant. / CIVIL ACTION SUMMONS PERSONAL SERVICE ON AN INDIVIDUAL IMPORTANTE EN ESPANOL AL DORSO IMPORTANT FRANCAIS AU VERSO TO: PRISCILLA JORDAN 645 WHITETAIL LOOP APOPKA, FL 32703-3120 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached Complaint in this Court. A phone call will not protect you; your written response, including the above case number and named parties, must be filed if you want the Court to hear your case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the Court. There are other legal requirements. You may want to call an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the Court located at: CLERK OF THE COURT ORANGE COUNTY COURTHOUSE 425 N. ORANGE AVE. ORLANDO, FL 32801 you must also mail or take a carbon copy or photocopy of your written response to the "Plaintiff's Attorney" named below: KEVIN SPINOZZA, ESQ. POLLACK & ROSEN, P.A. 806 DOUGLAS ROAD SOUTH TOWER-SUITE 200 CORAL GABLES, FLORIDA 33134 TELEPHONE NO: 305-448-0006 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons, a copy of the Complaint in this lawsuit on the above-named Defendant. Tiffany Moore Russell DATED ON 01.31 , 2022, Clerk of the Circuit Court Le £5;tS) (Court Seal) be 3] By /of Grace Katherine Uy Se Deputy Clerk SOON Givil Division 425 N. Orange Avenue Room 350 Orlandol, Florida 32801 MATTER