DEFENDANT'S SECOND MOTION TO DISMISS FORECLOSURE COMPLAINT (SRL) (REOPEN)

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IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT

                           IN AND FOR ALACHUA COUNTY, FLORIDA



                                                            CASE NO: 01-2023-CA-002552

                                                            Circuit Civil Division: MG (Foreclosures)

 PENNYMAC LOAN SERVICES, LLC.

 Plaintiff(s) vs.

 KARL STEPHEN SMITH II

 ALEKSANDRA TOMASEVIC

 Defendant

        DEFENDANT’S SECOND MOTION TO DISMISS FORECLOSURE COMPLAINT


Defendant provides the following records showing cause for Plaintiffs Foreclosure claim to be

dismissed on the grounds of Fraud and Misrepresentation.


    1    In previous Motion to Dismiss filing, Defendant produced records proving that Plaintiff's

         Foreclosure complaint, was filed on April 4, 2023, at which time Defendant was under an

          approved Forbearance Plan with Plaintiff, thru July 31, 2023.


         Court denied Defendant’s Motion to Dismiss but advised that Defendant could …