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Filing # 192965570 E-Filed 02/28/2024 05:17:24 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
SEACOAST NATIONAL BANK, s/b/m to
DRUMMOND COMMUNITY BANK,
Plaintiff,
VS. Case No.: 2024 CA 000136 A
Division:
EDITH BEAUCHAMP,
an individual, YURI AGUILA,
an individual, SANDERSON BAY FINE HOMES, LLC,
and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS,
SUB-SUB-CONTRACTORS, AND MATERIALMEN,
FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY
OWNERS’ ASSOCIATION, INC., and JOHN DOE
said John Doe beinga fictitious name signifying any
unknown party(ies) in possession under unrecorded leases
or otherwise,
Defendants.
ee
VERIFIED COMPLAINT
Plaintiff, SEACOAST NATIONAL BANK (“SEACOAST”) sues the Defendants, EDITH
BEAUCHAMP, (“BEAUCHAMP”), YURI AGUILA, (““AGUILA”), SANDERSON BAY FINE
HOMES, LLC, and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS, SUB-SUB-
CONTRACTORS, AND MATERIALMEN claiming thereunder (“SANDERSON BAY FINE
HOMES”), FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’ ASSOCIATION,
INC (“FAIRVIEW ESTATES”), and JOHN DOE, said John Doe being a fictitious name
signifying any unknown party(ies) in possession under unrecorded leases or otherwise
(collectively, ““Defendants”’), and alleges as follows:
ALLEGATIONS APPLICABLE TO ALL COUNTS
1. This is an action for breach of a promissory note, and to foreclose real property located
in Citrus County, Florida.
2. Defendant, BEAUCHAMP, is an individual who is over the age of 18 years and is
not a “person in the military service”, as that term is defined in 50 U.S.C. Appx. Sec. 511.
BEAUCHAMP is subject to the jurisdiction of this court.
3. Defendant, AGUILA is an individual who is over the age of 18 years and is not a
“person in the military service”, as that term is defined in 50 U.S.C. Appx. Sec. 511. AGUILA is
subject to the jurisdiction of this court.
4. Defendant, SANDERSON BAY FINE HOMES, is a Florida limited liability
company and is subject to the jurisdiction of this court.
5. Defendant, FAIRVIEW ESTATES is a Florida corporation with its principal
address in Hernando, Florida and is subject to the jurisdiction of this court.
6. Venue is proper in this Court pursuant to the terms of the Loan Documents, defined
infra.
7. All conditions precedent to the institution of this action have been performed or have
occurred.
8. SEACOAST has retained the undersigned law firm to represent it in this action and is
obligated to pay a reasonable fee for its services, which amounts are recoverable from BEAUCHAMP
and AGUILA pursuant to the Loan Documents described herein.
Loan Agreement *******500
9. On or about August 31, 2021, Drummond Community Bank and BEAUCHAMP
executed that certain construction loan agreement (“Construction Loan Agreement’). A true and
correct copy of the Construction Loan Agreement is attached hereto as Exhibit 1.
10. On or about August 31, 2021, in connection with the Construction Loan Agreement,
BEAUCHAMP executed and delivered to Drummond Community Bank that certain promissory
note, including a permanent loan rider to the same, non-amortizing period rider to the same, and a
construction allonge (collectively “Promissory Note”) in the principal amount of $315,000.00. A true
and correct copy of the Promissory Note is attached hereto as Exhibit 2 and incorporated herein.
11. On or about August 31, 2021, in connection with, and to secure repayment of the
Promissory Note, BEAUCHAMP and AGUILA, as husband and wife, executed and delivered a
mortgage, including an adjustable rate rider, planned unit development rider, and I-4 family rider
(collectively “Mortgage”’) to Drummond Community Bank encumbering the real property located in
Citrus County and bearing a legal description of:
Lot 15, Block C, FAIRVIEW ESTATES subdivision,
according to the plat recorded in Plat Book 12, Pages 49
through 60, inclusive, of the Public Records of Citrus
County, Florida.
Commonly known as 697 E. Foresthill Place, Hernando, Florida 34442 (“Property”).
12. The Mortgage was recorded in Citrus County Official Records as Instrument
Number 2021063512. A true and correct copy of the Mortgage is attached hereto as Exhibit 3 and
incorporated herein.
13. Onor about August 17, 2022, BEAUCHAMP executed and delivered to Drummond
Community Bank that certain note and mortgage modification agreement (“First Modification
Agreement’’) extending the construction period to November 30, 2022. A true and correct copy
of the First Modification Agreement is attached hereto as Exhibit 4 and incorporated herein.
14. On or about November 8, 2022, BEAUCHAMP executed and delivered to
Drummond Community Bank that certain note and mortgage modification agreement (“Second
Modification Agreement”) extending the construction period to February 28, 2023. A true and
correct copy of the Second Modification Agreement is attached hereto as Exhibit 5 and incorporated
herein.
15. On or about February 7, 2023, BEAUCHAMP executed and delivered to Drummond
Community Bank that certain note and mortgage modification agreement (“Third Modification
Agreement’) extending the construction period to August 31, 2023. A true and correct copy of the
Third Modification Agreement is attached hereto as Exhibit 6 and incorporated herein.
16. The Construction Loan Agreement, Promissory Note, Mortgage, and Promissory
Note, First Modification Agreement, Second Modification Agreement, and Third Modification
Agreement may hereinafter be collectively referred to as the “Loan Documents”.
17. Onor about October 7, 2022, Drummond Community Bank merged into SEACOAST
and SEACOAST became the owner and holder all of Drummond Community Bank’s assets,
including but not limited to the Construction Loan Agreement, Promissory Note, Mortgage, and
Promissory Note, First Modification Agreement, Second Modification Agreement, and Third
Modification Agreement.
18. SEACOAST is the owner and holder of Loan Documents, including the Construction
Loan Agreement, Promissory Note, Mortgage, and Promissory Note, First Modification Agreement,
Second Modification Agreement, and Third Modification Agreement and is entitled to enforce the
same.
Default
19. BEAUCHAMP defaulted on the Loan Documents by failing to make the monthly
payment on October 1, 2023, and all subsequent months thereafter as required under the terms of
the Loan Documents.
20. On December 5, 2023, SEACOAST, served a Notice of Default for the
aforementioned events of default demanding BEAUCHAMP to cure the same by making payment
on or before January 5, 2024. A true and correct copy of the Notice of Default attached hereto as
Exhibit 7 and incorporated herein.
21. BEAUCHAMP refused or failed to cure the events of default on or before January
5, 2024.
22. SEACOAST herein elects to accelerate the Promissory Note with the full balance
immediately due and owing to SEACOAST.
23. As of date of filing, the principal balance due under the Promissory Note is
$314,996.00.
24. Interest, fees, and all other charges properly due under the Promissory Note will
continue to accrue under the terms thereof.
25. SEACOAST has retained the undersigned law firm to represent it in this action and is
obligated to pay a reasonable fee for its services, which amounts are recoverable from the
BEAUCHAMP and AGUILA pursuant to Loan Documents.
COUNT
I
DAMAGES — BREACH OF PROMISSORY NOTE
26. This is an action for breach of the Promissory Note against BEAUCHAMP for
damages in excess of $50,000, exclusive of interest, court costs and attorneys’ fees.
27. SEACOAST reaffirms and realleges the Allegations Applicable to All Counts as if
fully set forth herein.
28. BEAUCHAMP breached the Promissory Note by failing to make the monthly
payment on October 1, 2023, and all subsequent months thereafter as required under the terms of
the same.
29. BEAUCHAMP failed to timely cure the breach of the Promissory Note.
30. SEACOAST elected to accelerate the full amount payable under the Promissory
Note to be due.
31. SEACOAST has been damaged by BEAUCHAMP in the principal amount of
$314,996.00, plus interest which continues to accrue as specified in the Promissory Note through
judgment.
WHEREFORE, SEACOAST requests this Court enter judgment against Defendant
BEAUCHAMP for damages for its breach of the Promissory Note, plus late charges, interest,
attorneys’ fees and costs and any further relief this Court deems just and proper.
COUNT
II
FORECLOSURE OF THE MORTGAGE
32. This is an action to foreclose the Mortgage.
33. SEACOAST realleges the Allegations Applicable To All Counts as though fully
set forth herein.
34, BEAUCHAMP and AGUILA, as husband and wife, defaulted under the terms of
the Loan Documents by failing to make the monthly payment on October 1, 2023, and all
subsequent months thereafter as required under the terms of the same.
35. The entire unpaid principal, together with accrued and unpaid interest and all other
charges due under the Mortgage, is now due and owing.
36. On account of the Mortgage and the Promissory Note, SEACOAST is due the
principal amount of $314,996.00 plus interest, late charges, attorney’s fees, taxes, insurance,
assessments and other sums which SEACOAST may become obligated to pay in order to the
property and title search expenses for ascertaining the necessary parties to this action, all of which
sums are secured by the lien of the Mortgage.
37. The following Defendants may claim an interest in the Property by virtue of the
documents described and/or facts alleged herein. However, such interests, if any, are inferior and
subordinate to the lien on the Mortgage.
a. EDITH BEAUCHAMP, by virtue of its ownership interest in the Property.
b. YURI AGUILA, by virtue of its ownership interest in the Property.
c. SANDERSON BAY FINE HOMES, ALL KNOWN OR UNKNOWN SUB-
CONTRACTORS, SUB-SUB-CONTRACTORS, AND MATERIALMEN
claiming thereunder, by virtue of a potential lien on the Property or other rights
under Florida law.
d. FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’
ASSOCIATION, INC., by virtue of a potential lien on the Property or other rights
under Florida law.
e. JOHN DOE, said John Doe being a fictitious name signifying any unknown
party(ies) in possession under unrecorded leases or otherwise.
38. | SEACOAST lacks an adequate remedy at law.
WHEREFORE, SEACOAST demands an accounting of the sums due to SEACOAST
under the Promissory Note and Mortgage, including principal, interest, late charges, costs, taxes,
assessments, insurance, title search expenses and reasonable attorney’s fee; that if such sum is not
paid within the time set by this Court, that the Property be sold to satisfy SEACOAST’s claim, and
if the proceeds of the sale are insufficient to pay SEACOAST’s claim, that a deficiency judgment
be entered for the sum remaining unpaid against Defendants, EDITH BEAUCHAMP, and YURI
AGUILA; that upon the issuance and delivery of the Certificate of Title to the successful bidder
and purchaser at the aforementioned sale, Defendant and any defendant in possession, if any, and
all other persons, firms and/or corporation claiming by, though, under, or against them, remove
themselves from the premises forthwith; and such further and other relief as this Court may deem
just and proper.
Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiffs’ counsel hereby designates its
primary email address as (¢\ison@elettermeys.comm and its secondary email as
admin2@elattormeys.com for service.
ELLISON | LAZENBY
/s J. Michael Lavin
Jason M. Ellison
FBN: 0040963
jellison@elattoracys.com
J. Michael Lavin
FBN: 1035323
nolavin@elationeys.com
150 Second Avenue North
Suite 1770
St. Petersburg, FL 33701
adinn2@clatiomeys.com
T: (727) 362-6151
Attorneys for Plaintiff
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
SEACOAST NATIONAL BANK, s/b/m to
DRUMMOND COMMUNITY BANK s/b/m
Plaintiff,
vs. Case No.:
Division:
EDITH BEAUCHAMP,
an individual, YURI AGUILA,
an individual, SANDERSON BAY FINE HOMES, LLC,
and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS,
SUB-SUB-CONTRACTORS, AND MATERIALMEN,
FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY
OWNERS’ ASSOCIATION, INC., and JOHN DOE
said John Doe beinga fictitious name signifying any
unknown party(ies) in possession under unrecorded leases
or otherwise.
Defendants.
/
VERIFICATION
Under penalty of perjury, I, Kevin Picart, as Senior Vice President of SEACOAST NATIONAL
BANK, declare that I have read the foregoing Verified Complaint, and the facts alleged therein are
true and correct to the best of my knowledge and belief.
— —_ —
Signature: | \ ey \
Print: Kevin Picart
Title: Senior Vice President
Date: 2/27/2024
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Filing # 192965570 E-Filed 02/28/2024 05:17:24 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION SEACOAST NATIONAL BANK, s/b/m to DRUMMOND COMMUNITY BANK, Plaintiff, VS. Case No.: 2024 CA 000136 A Division: EDITH BEAUCHAMP, an individual, YURI AGUILA, an individual, SANDERSON BAY FINE HOMES, LLC, and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS, SUB-SUB-CONTRACTORS, AND MATERIALMEN, FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’ ASSOCIATION, INC., and JOHN DOE said John Doe beinga fictitious name signifying any unknown party(ies) in possession under unrecorded leases or otherwise, Defendants. ee VERIFIED COMPLAINT Plaintiff, SEACOAST NATIONAL BANK (“SEACOAST”) sues the Defendants, EDITH BEAUCHAMP, (“BEAUCHAMP”), YURI AGUILA, (““AGUILA”), SANDERSON BAY FINE HOMES, LLC, and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS, SUB-SUB- CONTRACTORS, AND MATERIALMEN claiming thereunder (“SANDERSON BAY FINE HOMES”), FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’ ASSOCIATION, INC (“FAIRVIEW ESTATES”), and JOHN DOE, said John Doe being a fictitious name signifying any unknown party(ies) in possession under unrecorded leases or otherwise (collectively, ““Defendants”’), and alleges as follows: ALLEGATIONS APPLICABLE TO ALL COUNTS 1. This is an action for breach of a promissory note, and to foreclose real property located in Citrus County, Florida. 2. Defendant, BEAUCHAMP, is an individual who is over the age of 18 years and is not a “person in the military service”, as that term is defined in 50 U.S.C. Appx. Sec. 511. BEAUCHAMP is subject to the jurisdiction of this court. 3. Defendant, AGUILA is an individual who is over the age of 18 years and is not a “person in the military service”, as that term is defined in 50 U.S.C. Appx. Sec. 511. AGUILA is subject to the jurisdiction of this court. 4. Defendant, SANDERSON BAY FINE HOMES, is a Florida limited liability company and is subject to the jurisdiction of this court. 5. Defendant, FAIRVIEW ESTATES is a Florida corporation with its principal address in Hernando, Florida and is subject to the jurisdiction of this court. 6. Venue is proper in this Court pursuant to the terms of the Loan Documents, defined infra. 7. All conditions precedent to the institution of this action have been performed or have occurred. 8. SEACOAST has retained the undersigned law firm to represent it in this action and is obligated to pay a reasonable fee for its services, which amounts are recoverable from BEAUCHAMP and AGUILA pursuant to the Loan Documents described herein. Loan Agreement *******500 9. On or about August 31, 2021, Drummond Community Bank and BEAUCHAMP executed that certain construction loan agreement (“Construction Loan Agreement’). A true and correct copy of the Construction Loan Agreement is attached hereto as Exhibit 1. 10. On or about August 31, 2021, in connection with the Construction Loan Agreement, BEAUCHAMP executed and delivered to Drummond Community Bank that certain promissory note, including a permanent loan rider to the same, non-amortizing period rider to the same, and a construction allonge (collectively “Promissory Note”) in the principal amount of $315,000.00. A true and correct copy of the Promissory Note is attached hereto as Exhibit 2 and incorporated herein. 11. On or about August 31, 2021, in connection with, and to secure repayment of the Promissory Note, BEAUCHAMP and AGUILA, as husband and wife, executed and delivered a mortgage, including an adjustable rate rider, planned unit development rider, and I-4 family rider (collectively “Mortgage”’) to Drummond Community Bank encumbering the real property located in Citrus County and bearing a legal description of: Lot 15, Block C, FAIRVIEW ESTATES subdivision, according to the plat recorded in Plat Book 12, Pages 49 through 60, inclusive, of the Public Records of Citrus County, Florida. Commonly known as 697 E. Foresthill Place, Hernando, Florida 34442 (“Property”). 12. The Mortgage was recorded in Citrus County Official Records as Instrument Number 2021063512. A true and correct copy of the Mortgage is attached hereto as Exhibit 3 and incorporated herein. 13. Onor about August 17, 2022, BEAUCHAMP executed and delivered to Drummond Community Bank that certain note and mortgage modification agreement (“First Modification Agreement’’) extending the construction period to November 30, 2022. A true and correct copy of the First Modification Agreement is attached hereto as Exhibit 4 and incorporated herein. 14. On or about November 8, 2022, BEAUCHAMP executed and delivered to Drummond Community Bank that certain note and mortgage modification agreement (“Second Modification Agreement”) extending the construction period to February 28, 2023. A true and correct copy of the Second Modification Agreement is attached hereto as Exhibit 5 and incorporated herein. 15. On or about February 7, 2023, BEAUCHAMP executed and delivered to Drummond Community Bank that certain note and mortgage modification agreement (“Third Modification Agreement’) extending the construction period to August 31, 2023. A true and correct copy of the Third Modification Agreement is attached hereto as Exhibit 6 and incorporated herein. 16. The Construction Loan Agreement, Promissory Note, Mortgage, and Promissory Note, First Modification Agreement, Second Modification Agreement, and Third Modification Agreement may hereinafter be collectively referred to as the “Loan Documents”. 17. Onor about October 7, 2022, Drummond Community Bank merged into SEACOAST and SEACOAST became the owner and holder all of Drummond Community Bank’s assets, including but not limited to the Construction Loan Agreement, Promissory Note, Mortgage, and Promissory Note, First Modification Agreement, Second Modification Agreement, and Third Modification Agreement. 18. SEACOAST is the owner and holder of Loan Documents, including the Construction Loan Agreement, Promissory Note, Mortgage, and Promissory Note, First Modification Agreement, Second Modification Agreement, and Third Modification Agreement and is entitled to enforce the same. Default 19. BEAUCHAMP defaulted on the Loan Documents by failing to make the monthly payment on October 1, 2023, and all subsequent months thereafter as required under the terms of the Loan Documents. 20. On December 5, 2023, SEACOAST, served a Notice of Default for the aforementioned events of default demanding BEAUCHAMP to cure the same by making payment on or before January 5, 2024. A true and correct copy of the Notice of Default attached hereto as Exhibit 7 and incorporated herein. 21. BEAUCHAMP refused or failed to cure the events of default on or before January 5, 2024. 22. SEACOAST herein elects to accelerate the Promissory Note with the full balance immediately due and owing to SEACOAST. 23. As of date of filing, the principal balance due under the Promissory Note is $314,996.00. 24. Interest, fees, and all other charges properly due under the Promissory Note will continue to accrue under the terms thereof. 25. SEACOAST has retained the undersigned law firm to represent it in this action and is obligated to pay a reasonable fee for its services, which amounts are recoverable from the BEAUCHAMP and AGUILA pursuant to Loan Documents. COUNT I DAMAGES — BREACH OF PROMISSORY NOTE 26. This is an action for breach of the Promissory Note against BEAUCHAMP for damages in excess of $50,000, exclusive of interest, court costs and attorneys’ fees. 27. SEACOAST reaffirms and realleges the Allegations Applicable to All Counts as if fully set forth herein. 28. BEAUCHAMP breached the Promissory Note by failing to make the monthly payment on October 1, 2023, and all subsequent months thereafter as required under the terms of the same. 29. BEAUCHAMP failed to timely cure the breach of the Promissory Note. 30. SEACOAST elected to accelerate the full amount payable under the Promissory Note to be due. 31. SEACOAST has been damaged by BEAUCHAMP in the principal amount of $314,996.00, plus interest which continues to accrue as specified in the Promissory Note through judgment. WHEREFORE, SEACOAST requests this Court enter judgment against Defendant BEAUCHAMP for damages for its breach of the Promissory Note, plus late charges, interest, attorneys’ fees and costs and any further relief this Court deems just and proper. COUNT II FORECLOSURE OF THE MORTGAGE 32. This is an action to foreclose the Mortgage. 33. SEACOAST realleges the Allegations Applicable To All Counts as though fully set forth herein. 34, BEAUCHAMP and AGUILA, as husband and wife, defaulted under the terms of the Loan Documents by failing to make the monthly payment on October 1, 2023, and all subsequent months thereafter as required under the terms of the same. 35. The entire unpaid principal, together with accrued and unpaid interest and all other charges due under the Mortgage, is now due and owing. 36. On account of the Mortgage and the Promissory Note, SEACOAST is due the principal amount of $314,996.00 plus interest, late charges, attorney’s fees, taxes, insurance, assessments and other sums which SEACOAST may become obligated to pay in order to the property and title search expenses for ascertaining the necessary parties to this action, all of which sums are secured by the lien of the Mortgage. 37. The following Defendants may claim an interest in the Property by virtue of the documents described and/or facts alleged herein. However, such interests, if any, are inferior and subordinate to the lien on the Mortgage. a. EDITH BEAUCHAMP, by virtue of its ownership interest in the Property. b. YURI AGUILA, by virtue of its ownership interest in the Property. c. SANDERSON BAY FINE HOMES, ALL KNOWN OR UNKNOWN SUB- CONTRACTORS, SUB-SUB-CONTRACTORS, AND MATERIALMEN claiming thereunder, by virtue of a potential lien on the Property or other rights under Florida law. d. FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’ ASSOCIATION, INC., by virtue of a potential lien on the Property or other rights under Florida law. e. JOHN DOE, said John Doe being a fictitious name signifying any unknown party(ies) in possession under unrecorded leases or otherwise. 38. | SEACOAST lacks an adequate remedy at law. WHEREFORE, SEACOAST demands an accounting of the sums due to SEACOAST under the Promissory Note and Mortgage, including principal, interest, late charges, costs, taxes, assessments, insurance, title search expenses and reasonable attorney’s fee; that if such sum is not paid within the time set by this Court, that the Property be sold to satisfy SEACOAST’s claim, and if the proceeds of the sale are insufficient to pay SEACOAST’s claim, that a deficiency judgment be entered for the sum remaining unpaid against Defendants, EDITH BEAUCHAMP, and YURI AGUILA; that upon the issuance and delivery of the Certificate of Title to the successful bidder and purchaser at the aforementioned sale, Defendant and any defendant in possession, if any, and all other persons, firms and/or corporation claiming by, though, under, or against them, remove themselves from the premises forthwith; and such further and other relief as this Court may deem just and proper. Pursuant to Fla. R. Jud. Admin. 2.516(b)(1)(A), Plaintiffs’ counsel hereby designates its primary email address as (¢\ison@elettermeys.comm and its secondary email as admin2@elattormeys.com for service. ELLISON | LAZENBY /s J. Michael Lavin Jason M. Ellison FBN: 0040963 jellison@elattoracys.com J. Michael Lavin FBN: 1035323 nolavin@elationeys.com 150 Second Avenue North Suite 1770 St. Petersburg, FL 33701 adinn2@clatiomeys.com T: (727) 362-6151 Attorneys for Plaintiff IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION SEACOAST NATIONAL BANK, s/b/m to DRUMMOND COMMUNITY BANK s/b/m Plaintiff, vs. Case No.: Division: EDITH BEAUCHAMP, an individual, YURI AGUILA, an individual, SANDERSON BAY FINE HOMES, LLC, and ALL KNOWN OR UNKNOWN SUB-CONTRACTORS, SUB-SUB-CONTRACTORS, AND MATERIALMEN, FAIRVIEW ESTATES OF CITRUS HILLS PROPERTY OWNERS’ ASSOCIATION, INC., and JOHN DOE said John Doe beinga fictitious name signifying any unknown party(ies) in possession under unrecorded leases or otherwise. Defendants. / VERIFICATION Under penalty of perjury, I, Kevin Picart, as Senior Vice President of SEACOAST NATIONAL BANK, declare that I have read the foregoing Verified Complaint, and the facts alleged therein are true and correct to the best of my knowledge and belief. — —_ — Signature: | \ ey \ Print: Kevin Picart Title: Senior Vice President Date: 2/27/2024