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  • AURORA LOAN SERVICES LLC V SIMPSON, STEPHEN REAL PROPERTY/FORECLOSURE document preview
  • AURORA LOAN SERVICES LLC V SIMPSON, STEPHEN REAL PROPERTY/FORECLOSURE document preview
						
                                

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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA024086XXXXMBAW AURORA LOAN SERVICES, LLC, Plaintiff, vs. STEPHEN SIMPSON, ET AL., Defendants. / CROSS-PLAINTIFF MARINE CONSTRUCTION’ S MOTION FOR FINAL SUMMARY JUDGMENT AGAINST CROSS-DEFENDANT STEPHEN SIMPSON COMES NOW the Cross-Plaintiff, Marine Construction, Inc., by and through its undersigned counsel, pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, and hereby moves this Honorable Court for entry of a final summary judgment against Cross-Defendant Stephen Simpson. This motion is made on the grounds that there is no genuine issue as to any material fact and that said Cross-Plaintiff is entitled to judgment as a matter of law because said Cross- Defendant entered into a construction contract with the Plaintiff, the Plaintiff has completed its work, but said Cross-Defendant has failed to pay said Cross-Plaintiff. The Cross-Defendant is in default for failing to respond to the Cross-Plaintiff's cross- claim. WHEREFORE, the Cross-Plaintiff seeks judgment against the Cross-Defendant as follows:1. For $17,200.00, plus interest as provided by law. 2. For costs of suit and attorney’s fees. 3. For such other and further relief this Court may deem just and proper. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to Stephen Simpson and Kristina T. Simpson, 190 Arlington Road, West Palm Beach, FL 33405, Elizabeth M. Ferrell, Esquire, Law Offices of David J. Stern, P.A., 900 South Pine Island Road, Suite 400, Plantation, FL 33324-3920 and to John P. Koplitz, Esquire, 9204 King Palm Drive, Tampa, FL 33619 this ay of J 2008. RAYMOND M. MASCIARELLA II, PA By: Raymond M. Masciarella II, Esquire Florida Bar Number: 441716 840 U. S. Highway One, Suite 340 North Palm Beach, FL 33408 Telephone (561) 627-4448 Facsimile (561) 627-4495 Attorney for Marine Construction