On November 11, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
U.S. Bank Trust, N.A.,
and
Kozel, Charles C.,
Kozel, Lana S.,
Unknown Party 1,
Unknown Party 2,
Unknown Party 3,
Unknown Party 4,
for Civil
in the District Court of Hillsborough County.
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Filing # 125261210 E-Filed 04/20/2021 02:23:07 PM
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
U.S. BANK TRUST N.A., AS TRUSTEE FOR CASE NO.: 19-CA-011544
LSF10 MASTER PARTICIPATION TRUST,
Plaintiff,
VS.
CHARLES C. KOZEL; et al.,
Defendant(s).
/
PLAINTIFF’S MOTION FOR SUBSTITUTION OF COUNSEL
The undersigned, pursuant to Rule 2.505(e)(2), Fla. R. Jud. Admin., hereby moves to be
substituted as counsel of record for Plaintiff, US. BANK TRUST N.A., AS TRUSTEE FOR
LSF10 MASTER PARTICIPATION TRUST, in this action in place of Albertelli Law and states:
1 Undersigned counsel has been engaged to assume legal representation of Plaintiff in this
action in place of Albertelli Law.
Rule 2.505(e)(2), Fla. R. Jud. Admin. provides: “(e) Appearance of Attorney. An attorney
may appear in a proceeding in any of the following ways: ... (2) By substitution of counsel,
but only by order of court and with written consent of the client, filed with the court. The
court may condition substitution upon payment of, or security for, the substituted attorney’s
fees and expenses, or upon such other terms as may be just.”
Letters indicating consent to substitution of counsel have been executed on behalf of
Plaintiff, copies of which are attached hereto.
Plaintiff asserts that there may be a related Bankruptcy case pending, therefore this Motion
is being filed to update the Court for Notice purposes only, and is not intended to advance
the Foreclosure action.
1221-5499B
4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 1
5. The requested substitution will further the interests of justice and will not prejudice any
party.
WHEREFORE, undersigned counsel requests an order granting its substitution as counsel of
record for Plaintiff, U.S. BANK TRUST N.A., AS TRUSTEE FOR LSF10 MASTER
PARTICIPATION TRUST, in this action in place of Albertelli Law.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via E-Mail
or Regular U.S. Mail to the parties listed on the service list on this Qo day of A
2021.
ALDRIDGE PITE, LLP
Attorney for Plaintiff
1615 South Congress Avenue, Suite 200
Delray Beach, FL 33445
Telephone: 561- 2-6391
Facsimjle*561-3926965
aro
FBN: FBN 44927
Primary E-Mail: ServiceMail@aldridgepite.com
Service List:
By U.S. Mail:
Charles C. Kozel
8816 Ashman Road
Riverview, FL 33578
Lana S. Kozel a/k/a Lana Kozel
8816 Ashman Road
Riverview, FL 33578
1221-5499B
4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 2
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR
HILLSBOROUGH COUNTY, FLORIDA.
U.S. BANK TRUST, N.A.,; AS TRUSTEE CASE NO:: 19-CA-011544
FOR LSFIO MASTER PARTICIPATION
TRUST,
Plaintiff, i
VS
CHARLES C. KOZEL; et al.
Defendant(s).
CLIENT CONSENT TO SUBSTITUTION OF COUNSEL
Pursuant to Rule 2.505(€)(2), Florida Rules of Judicial Administration, U.S. BANK. |
TRUST, N.A., AS TRUSTEE FOR LSFIO MASTER PARTICIPATION TRUST, hereby
i
consents to: ALDRIDGE PITE, LLP substituting into this case as its:counsel iin place of Albertelli
Law.
FAY SERVICING, LLC,-AS ATTORNEY-IN-
FACT FOR ANK. TRUST NATIONAL
ASSOC! IT IVIDUAL i
CAPACI
Ls
', BUT SOLELY AS TRUSTEE OF
ER PARTICIPATION TRUST |1
By: a pe
Print Name’ Priscilla Serrato
Title: Assistant Secretary
1221-54998
4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 3
Document Filed Date
April 20, 2021
Case Filing Date
November 11, 2019
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Filing # 125261210 E-Filed 04/20/2021 02:23:07 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA U.S. BANK TRUST N.A., AS TRUSTEE FOR CASE NO.: 19-CA-011544 LSF10 MASTER PARTICIPATION TRUST, Plaintiff, VS. CHARLES C. KOZEL; et al., Defendant(s). / PLAINTIFF’S MOTION FOR SUBSTITUTION OF COUNSEL The undersigned, pursuant to Rule 2.505(e)(2), Fla. R. Jud. Admin., hereby moves to be substituted as counsel of record for Plaintiff, US. BANK TRUST N.A., AS TRUSTEE FOR LSF10 MASTER PARTICIPATION TRUST, in this action in place of Albertelli Law and states: 1 Undersigned counsel has been engaged to assume legal representation of Plaintiff in this action in place of Albertelli Law. Rule 2.505(e)(2), Fla. R. Jud. Admin. provides: “(e) Appearance of Attorney. An attorney may appear in a proceeding in any of the following ways: ... (2) By substitution of counsel, but only by order of court and with written consent of the client, filed with the court. The court may condition substitution upon payment of, or security for, the substituted attorney’s fees and expenses, or upon such other terms as may be just.” Letters indicating consent to substitution of counsel have been executed on behalf of Plaintiff, copies of which are attached hereto. Plaintiff asserts that there may be a related Bankruptcy case pending, therefore this Motion is being filed to update the Court for Notice purposes only, and is not intended to advance the Foreclosure action. 1221-5499B 4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 1 5. The requested substitution will further the interests of justice and will not prejudice any party. WHEREFORE, undersigned counsel requests an order granting its substitution as counsel of record for Plaintiff, U.S. BANK TRUST N.A., AS TRUSTEE FOR LSF10 MASTER PARTICIPATION TRUST, in this action in place of Albertelli Law. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was provided via E-Mail or Regular U.S. Mail to the parties listed on the service list on this Qo day of A 2021. ALDRIDGE PITE, LLP Attorney for Plaintiff 1615 South Congress Avenue, Suite 200 Delray Beach, FL 33445 Telephone: 561- 2-6391 Facsimjle*561-3926965 aro FBN: FBN 44927 Primary E-Mail: ServiceMail@aldridgepite.com Service List: By U.S. Mail: Charles C. Kozel 8816 Ashman Road Riverview, FL 33578 Lana S. Kozel a/k/a Lana Kozel 8816 Ashman Road Riverview, FL 33578 1221-5499B 4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 2 IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT IN AND FOR HILLSBOROUGH COUNTY, FLORIDA. U.S. BANK TRUST, N.A.,; AS TRUSTEE CASE NO:: 19-CA-011544 FOR LSFIO MASTER PARTICIPATION TRUST, Plaintiff, i VS CHARLES C. KOZEL; et al. Defendant(s). CLIENT CONSENT TO SUBSTITUTION OF COUNSEL Pursuant to Rule 2.505(€)(2), Florida Rules of Judicial Administration, U.S. BANK. | TRUST, N.A., AS TRUSTEE FOR LSFIO MASTER PARTICIPATION TRUST, hereby i consents to: ALDRIDGE PITE, LLP substituting into this case as its:counsel iin place of Albertelli Law. FAY SERVICING, LLC,-AS ATTORNEY-IN- FACT FOR ANK. TRUST NATIONAL ASSOC! IT IVIDUAL i CAPACI Ls ', BUT SOLELY AS TRUSTEE OF ER PARTICIPATION TRUST |1 By: a pe Print Name’ Priscilla Serrato Title: Assistant Secretary 1221-54998 4/20/2021 2:23 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 3