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Filing # 49904732 E-Filed 12/12/2016 01:08:49 PM
IN THE CIRCUIT COURT, IN AND FOR
ORANGE COUNTY, FLORIDA
CASE NO.: 2016-CA-8362-O
QUALITY ONE WIRELESS, LLC,
Plaintiff,
v.
LIQUID IMAGE CO., LLC,
Defendant,
v.
WELLS FARGO BANK, N.A.,
Garnishee.
/
ANSWER OF GARNISHEE
AND
DEMAND FOR GARNISHMENT FEE
COMES NOW Garnishee, Wells Fargo Bank, N.A., successor in interest to Wachovia
Bank, N.A., by and through its undersigned attorneys, and answers the Writ of Garnishment
served herein on it and says:
1. At the time of service of said Writ (plus sufficient time not to exceed one business
day for Garnishee to act expeditiously on the Writ), and at the time of this Answer, and in
between said times, excluding any “protected amount” as defined in Title 31, Subtitle B, Chapter
II, Subchapter A, Part 212, Code of Federal Regulations, if any, the Garnishee was not
indebted to Defendant(s), “Liquid Image Co., LLC”.
2. The Garnishee has no other deposit, account or tangible or intangible personal
property of Defendant(s) in its possession or control at the time of this Answer, and knows of no
other person indebted to the Defendant(s) or who may have any of the effects of the
Defendant(s).
105422716
3. The Garnishee has retained the law firm of Marks Gray, P.A. to represent it in this
matter and requests that it be paid its attorney's fees and costs as allowed by Florida Statute
Section 77.28.
DEMAND FOR GARNISHMENT FEE
The Plaintiff/Plaintiff’s Counsel shall pay to the undersigned Law Firm the $100.00
partial attorney’s fee for issuance of the garnishment Writ in the above-style cause pursuant to
Section 77.28, Florida Statutes, as amended effective July 1, 2014.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that copy hereof has been furnished to the email or mail addresses
listed on the attached Service List by email or mail on December 12, 2016.
MARKS GRAY, P.A.
By
John B. Kent
Florida Bar No. 042442
P.O. Box 447
Jacksonville, FL 32201
Telephone: (904) 398-0900
Facsimile: (904) 399-8440
jkent@marksgray.com
Attorneys for Garnishee
SERVICE LIST
Charles C. Lane, Esq.
Lau, Lane, Pieper, Conley & McCreadie, P.A.
(clane@laulane.com)
105422716
WELLS FARGO BANK,N.A.
To all Plaintiffs/ Plaintiffs' Attorneys/ Creditors/ Creditors' Attorneys causing the
Issuance ofa Writ of Garnishment in the State of Florida:.
Re:Payment ofthe $100 Statutory Deposit
to Garnishee for its Attorneys Fee
Ladies / Gentlemen:
We hereby make Demand for, and Direct all Plaintiffs/ Plaintiffs' Attorneys/
Creditors/ Creditors' Attorneys causing the Issuance of a Writ of Garnishment in the
State of Florida, to pay directly to our attorneys the $100.00 deposit for the payment or
partial payment of Garnishee's attorneys' fees "Upon issuance of any writ of
garnishment', which, pursuant to Chapter 77, Florida Statutes, as amended as of July 1,
2014, is due to Wells Fargo Bank, N.A.,as Garnishee, based on itsdemand therefor.
Our attorney's address is:
John B. Kent, Esquire
Marks Gray,P.A.
1200 Riverplace Boulevard, Suite 800
Jacksonville, Florida 32207
Taxpayer Identification Number: 59-1514046
We appreciate your cooperation.
Sincerely yours,
(tr—N
Erica Cook
Legal Order Processing Department
Wells Fargo Bank, N.A.
Please reference the Wells Fargo Bank File Number shown on the bottom left comer of
the Garnishee's Answer on the memo portion of the Check. Thank you!
Preview
Filing # 49904732 E-Filed 12/12/2016 01:08:49 PM IN THE CIRCUIT COURT, IN AND FOR ORANGE COUNTY, FLORIDA CASE NO.: 2016-CA-8362-O QUALITY ONE WIRELESS, LLC, Plaintiff, v. LIQUID IMAGE CO., LLC, Defendant, v. WELLS FARGO BANK, N.A., Garnishee. / ANSWER OF GARNISHEE AND DEMAND FOR GARNISHMENT FEE COMES NOW Garnishee, Wells Fargo Bank, N.A., successor in interest to Wachovia Bank, N.A., by and through its undersigned attorneys, and answers the Writ of Garnishment served herein on it and says: 1. At the time of service of said Writ (plus sufficient time not to exceed one business day for Garnishee to act expeditiously on the Writ), and at the time of this Answer, and in between said times, excluding any “protected amount” as defined in Title 31, Subtitle B, Chapter II, Subchapter A, Part 212, Code of Federal Regulations, if any, the Garnishee was not indebted to Defendant(s), “Liquid Image Co., LLC”. 2. The Garnishee has no other deposit, account or tangible or intangible personal property of Defendant(s) in its possession or control at the time of this Answer, and knows of no other person indebted to the Defendant(s) or who may have any of the effects of the Defendant(s). 105422716 3. The Garnishee has retained the law firm of Marks Gray, P.A. to represent it in this matter and requests that it be paid its attorney's fees and costs as allowed by Florida Statute Section 77.28. DEMAND FOR GARNISHMENT FEE The Plaintiff/Plaintiff’s Counsel shall pay to the undersigned Law Firm the $100.00 partial attorney’s fee for issuance of the garnishment Writ in the above-style cause pursuant to Section 77.28, Florida Statutes, as amended effective July 1, 2014. CERTIFICATE OF SERVICE I HEREBY CERTIFY that copy hereof has been furnished to the email or mail addresses listed on the attached Service List by email or mail on December 12, 2016. MARKS GRAY, P.A. By John B. Kent Florida Bar No. 042442 P.O. Box 447 Jacksonville, FL 32201 Telephone: (904) 398-0900 Facsimile: (904) 399-8440 jkent@marksgray.com Attorneys for Garnishee SERVICE LIST Charles C. Lane, Esq. Lau, Lane, Pieper, Conley & McCreadie, P.A. (clane@laulane.com) 105422716 WELLS FARGO BANK,N.A. To all Plaintiffs/ Plaintiffs' Attorneys/ Creditors/ Creditors' Attorneys causing the Issuance ofa Writ of Garnishment in the State of Florida:. Re:Payment ofthe $100 Statutory Deposit to Garnishee for its Attorneys Fee Ladies / Gentlemen: We hereby make Demand for, and Direct all Plaintiffs/ Plaintiffs' Attorneys/ Creditors/ Creditors' Attorneys causing the Issuance of a Writ of Garnishment in the State of Florida, to pay directly to our attorneys the $100.00 deposit for the payment or partial payment of Garnishee's attorneys' fees "Upon issuance of any writ of garnishment', which, pursuant to Chapter 77, Florida Statutes, as amended as of July 1, 2014, is due to Wells Fargo Bank, N.A.,as Garnishee, based on itsdemand therefor. Our attorney's address is: John B. Kent, Esquire Marks Gray,P.A. 1200 Riverplace Boulevard, Suite 800 Jacksonville, Florida 32207 Taxpayer Identification Number: 59-1514046 We appreciate your cooperation. Sincerely yours, (tr—N Erica Cook Legal Order Processing Department Wells Fargo Bank, N.A. Please reference the Wells Fargo Bank File Number shown on the bottom left comer of the Garnishee's Answer on the memo portion of the Check. Thank you!