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Filing # 167478762 E-Filed 02/24/2023 10:36:08 AM
IN THE COUNTY COURT OF THE 12TH JUDICIAL CIRCUIT
IN AND FOR MANATEE COUNTY, FLORIDA
CASE NO: 2022-CC-006972
THE TOWNHOMES AT LIGHTHOUSE COVE Iii
CONDOMINIUM ASSOCIATION, INC.,
a not-for-profit Florida corporation,
Plaintiff,
VS.
ILIA T KONDRATIEV; ALEXANDRA KONDRATIEVA
AND UNKNOWN TENANT(S)
;Defendants.
/
JOINT STIPULATION OF SETTLEMENT
COMES NOW, Plaintiff, THE TOWNHOMES AT LIGHTHOUSE COVE III
CONDOMINIUM ASSOCIATION, INC, by and through its undersigned counsel, and the
Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA, said parties having
stipulated and agreed to the following in the within cause of action:
1. Plaintiff, THE TOWNHOMES AT LIGHTHOUSE COVE [il CONDOMINIUM
ASSOCIATION, INC, and Defendants, ILIA T KONDRATIEV and ALEXANDRA
KONDRATIEVA hereby enter into the following agreement and acknowledge that the
amount of $11,958.80, which represents past due assessments, collection costs, interest,
and attorney fees, through December 31, 2022, and is further broken down as follows:
$7,005.00 Principal through December 31, 2022
$ 3,003.50 Attorney Fees
$ 1,382.10 Interest
$ 568.20 Court Costs
$11,958.80 TOTAL
In order to satisfy this obligation, the Defendants, ILIA T KONDRATIEV and
ALEXANDRA KONDRATIEVA stipulates and agrees to an payments in the amount of
$996.56 month, due and payable on the (15th) day of each successive month thereafer ,
"2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST
in addition to paying all future assessments as they come due. Failure to pay the on-
going assessments will result in a revocation of this agreement.
Payments shall be submitted to Plaintiff's counsel in the form ofa certified check or money
order, payable to the Mankin Law Group Trust Account, and will be mailed to 2535
Landmark Drive, Suite 212, Clearwater, FL 33761.
the
Additional assessments will continue to accrue in the future and will be paid outside
nt
terms of this agreement. Any additional overage paid will be applied toward the delinque
amounts set forth in paragraph (1).
to
The Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA, agree
bear their own attorney’s fees and costs in the present cause of action.
The Defendants, [LA T KONDRATIEV and ALEXANDRA KONDRATIEVA, further
the
stipulates and agrees, that in the event that Defendant refinances the mortgage(s) on
shall
property or sell the subject property, the entire unpaid sum owed to the Plaintiff,
immediately be due.
In the event of a default, Defendants, ILIA T KONDRATIEV and ALEXANDRA
to an
KONDRATIEVA, hereby stipulates and agrees that the Plaintiff would be entitled
to
Amended Final Judgment of Foreclosure as well as additional fees and costs related
same and that the Court shall reserve the right to set a Sale Date in this matter.
to
Upon the receipt of Defendants full and complete payment of the settlement pursuant
a
the binding payment arrangement described in paragraph (1) above, Plaintiff shall file
to the within
Notice of Dismissal, Release of Lis Pendens, and Release of Lien in regards
action.
the Joint
The parties stipulate and agree that the parties have had sufficient time to review
ons herein.
Stipulation for Settlement and understand and agree to all the terms and provisi
"2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST
the
This Joint Stipulation for Settlement constitutes the full and complete agreement of
parties in the present cause of action and there are no agreements or understandings
nt.
between the parties which are not expressly set forth in this Joint Stipulation for Settleme
The parties further stipulate and agree that this Court shall retain jurisdiction of the parties
in this cause of action to enforce the Joint Stipulation, should the need arise.
D; By ot Feo 2023 Dated this 020 __ day of February 2023
~,
IA T KONDRATIEV
FLBa #0
MANKIN LAW GROUP
2535 Landmark Drive, Suite 212
Clearwater, FL 33761 KONDRATIEVA
CERTIFICATE OF SERVICE
d by
1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnishe
US. Mail on this £0 day of February 2023
Loop, #107,
ILIA TKONDRATIEV and ALEXANDRA KONDRATIEVA 238 Cape Harbour
Bradenton, FL 34212
poNe
zie UU
p—
RR HOW K. MOLLIS, £8
Attorh s for Plaintiff
Service(@MankinLawGroup.com
2535 Landmark Drive, Suite 212
Clearwater, FL 33761
‘Telephone: (727) 725-0559
FBN: 0023217
"2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST
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Filing # 167478762 E-Filed 02/24/2023 10:36:08 AM IN THE COUNTY COURT OF THE 12TH JUDICIAL CIRCUIT IN AND FOR MANATEE COUNTY, FLORIDA CASE NO: 2022-CC-006972 THE TOWNHOMES AT LIGHTHOUSE COVE Iii CONDOMINIUM ASSOCIATION, INC., a not-for-profit Florida corporation, Plaintiff, VS. ILIA T KONDRATIEV; ALEXANDRA KONDRATIEVA AND UNKNOWN TENANT(S) ;Defendants. / JOINT STIPULATION OF SETTLEMENT COMES NOW, Plaintiff, THE TOWNHOMES AT LIGHTHOUSE COVE III CONDOMINIUM ASSOCIATION, INC, by and through its undersigned counsel, and the Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA, said parties having stipulated and agreed to the following in the within cause of action: 1. Plaintiff, THE TOWNHOMES AT LIGHTHOUSE COVE [il CONDOMINIUM ASSOCIATION, INC, and Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA hereby enter into the following agreement and acknowledge that the amount of $11,958.80, which represents past due assessments, collection costs, interest, and attorney fees, through December 31, 2022, and is further broken down as follows: $7,005.00 Principal through December 31, 2022 $ 3,003.50 Attorney Fees $ 1,382.10 Interest $ 568.20 Court Costs $11,958.80 TOTAL In order to satisfy this obligation, the Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA stipulates and agrees to an payments in the amount of $996.56 month, due and payable on the (15th) day of each successive month thereafer , "2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST in addition to paying all future assessments as they come due. Failure to pay the on- going assessments will result in a revocation of this agreement. Payments shall be submitted to Plaintiff's counsel in the form ofa certified check or money order, payable to the Mankin Law Group Trust Account, and will be mailed to 2535 Landmark Drive, Suite 212, Clearwater, FL 33761. the Additional assessments will continue to accrue in the future and will be paid outside nt terms of this agreement. Any additional overage paid will be applied toward the delinque amounts set forth in paragraph (1). to The Defendants, ILIA T KONDRATIEV and ALEXANDRA KONDRATIEVA, agree bear their own attorney’s fees and costs in the present cause of action. The Defendants, [LA T KONDRATIEV and ALEXANDRA KONDRATIEVA, further the stipulates and agrees, that in the event that Defendant refinances the mortgage(s) on shall property or sell the subject property, the entire unpaid sum owed to the Plaintiff, immediately be due. In the event of a default, Defendants, ILIA T KONDRATIEV and ALEXANDRA to an KONDRATIEVA, hereby stipulates and agrees that the Plaintiff would be entitled to Amended Final Judgment of Foreclosure as well as additional fees and costs related same and that the Court shall reserve the right to set a Sale Date in this matter. to Upon the receipt of Defendants full and complete payment of the settlement pursuant a the binding payment arrangement described in paragraph (1) above, Plaintiff shall file to the within Notice of Dismissal, Release of Lis Pendens, and Release of Lien in regards action. the Joint The parties stipulate and agree that the parties have had sufficient time to review ons herein. Stipulation for Settlement and understand and agree to all the terms and provisi "2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST the This Joint Stipulation for Settlement constitutes the full and complete agreement of parties in the present cause of action and there are no agreements or understandings nt. between the parties which are not expressly set forth in this Joint Stipulation for Settleme The parties further stipulate and agree that this Court shall retain jurisdiction of the parties in this cause of action to enforce the Joint Stipulation, should the need arise. D; By ot Feo 2023 Dated this 020 __ day of February 2023 ~, IA T KONDRATIEV FLBa #0 MANKIN LAW GROUP 2535 Landmark Drive, Suite 212 Clearwater, FL 33761 KONDRATIEVA CERTIFICATE OF SERVICE d by 1 HEREBY CERTIFY that a true and correct copy of the foregoing has been furnishe US. Mail on this £0 day of February 2023 Loop, #107, ILIA TKONDRATIEV and ALEXANDRA KONDRATIEVA 238 Cape Harbour Bradenton, FL 34212 poNe zie UU p— RR HOW K. MOLLIS, £8 Attorh s for Plaintiff Service(@MankinLawGroup.com 2535 Landmark Drive, Suite 212 Clearwater, FL 33761 ‘Telephone: (727) 725-0559 FBN: 0023217 "2022CC006972AX" 167478762 Filed at Manatee County Clerk 02/24/2023 10:36:07 AM EST