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Filing # 122276879 E-Filed 03/01/2021 05:16:06 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT,
IN AND FOR BROWARD COUNTY, FLORIDA
VILLA MEDICI ASSOCIATION, INC., a CASE NO: CONO 20-20062
Florida non-profit Corporation,
Plaintiff
V.
SOLACE EQUITY FINANCE, LLC;
SJ MAK, LLC; WELLS FARGO BANK N.A,
AND UNKNOWN TENANT, ETAL.
Defendant
/
DEFENDANT SJ MAK, LLC_ ANSWER
COMES NOW, Defendant SJ MAK, LLC; by and through undersigned counsel, and files
this its answer to the complaint and states as follows:
1. Defendant admits the allegations contained in paragraphs 1,2,3,5,8,11,27 and 28 of the
complaint.
2. Defendant admits in part the allegations contained within paragraph 31 of the complaint,
specifically that defendant holds a mortgage on the subject property. The remainder of the
allegations contained within the paragraph are denied.
3. Defendant denies the allegations contained within paragraph 15 of the complaint.
4. Defendant is without knowledge as to the allegations contained within paragraphs
4,67,9,10,12,13,14,16, 18, 19, 20, 21, 22, 23, 25, 26, 29, 30, 32 and of the complaint therefore
they are deemed denied.
5. As to paragraphs 17 and 24 of the complaint Defendant realleges and reavers its prior responses
as if fully set forth herein.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2021 05:16:05 PM.**#*
WHEREFORE, Defendant SJ Mak, ask that this Court enter judgment in its factors, award it
attomeys fees and costs and such other relief that the Court deem just and equitable.
/s/ Robert Flavell
Robert Flavell, Esq.
FBN: 909203
1420 Celebration Boulevard,
Suite 200
Celebration, FL 34747
Tel: 305-362-9010
407-815-5377
Fax: 407-815-5477
Eservice: eservice@rfpa.net
Rflavellesquire@gmail.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a correct and true copy of the foregoing was served via email
pursuant to Fla.R.Jud.Admin. 2.516, to Kathy L. Houston, Esq., at attorney@91 1 foreclosure.com.
and Nicholas Randall, Esq., mgr@911foreclosure.com; on this 1‘ day of March, 2021.
/s/ Robert Flavell
Robert Flavell, Esq.
FBN: 909203
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Filing # 122276879 E-Filed 03/01/2021 05:16:06 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA VILLA MEDICI ASSOCIATION, INC., a CASE NO: CONO 20-20062 Florida non-profit Corporation, Plaintiff V. SOLACE EQUITY FINANCE, LLC; SJ MAK, LLC; WELLS FARGO BANK N.A, AND UNKNOWN TENANT, ETAL. Defendant / DEFENDANT SJ MAK, LLC_ ANSWER COMES NOW, Defendant SJ MAK, LLC; by and through undersigned counsel, and files this its answer to the complaint and states as follows: 1. Defendant admits the allegations contained in paragraphs 1,2,3,5,8,11,27 and 28 of the complaint. 2. Defendant admits in part the allegations contained within paragraph 31 of the complaint, specifically that defendant holds a mortgage on the subject property. The remainder of the allegations contained within the paragraph are denied. 3. Defendant denies the allegations contained within paragraph 15 of the complaint. 4. Defendant is without knowledge as to the allegations contained within paragraphs 4,67,9,10,12,13,14,16, 18, 19, 20, 21, 22, 23, 25, 26, 29, 30, 32 and of the complaint therefore they are deemed denied. 5. As to paragraphs 17 and 24 of the complaint Defendant realleges and reavers its prior responses as if fully set forth herein. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/01/2021 05:16:05 PM.**#* WHEREFORE, Defendant SJ Mak, ask that this Court enter judgment in its factors, award it attomeys fees and costs and such other relief that the Court deem just and equitable. /s/ Robert Flavell Robert Flavell, Esq. FBN: 909203 1420 Celebration Boulevard, Suite 200 Celebration, FL 34747 Tel: 305-362-9010 407-815-5377 Fax: 407-815-5477 Eservice: eservice@rfpa.net Rflavellesquire@gmail.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a correct and true copy of the foregoing was served via email pursuant to Fla.R.Jud.Admin. 2.516, to Kathy L. Houston, Esq., at attorney@91 1 foreclosure.com. and Nicholas Randall, Esq., mgr@911foreclosure.com; on this 1‘ day of March, 2021. /s/ Robert Flavell Robert Flavell, Esq. FBN: 909203