Document for Ajax Mortgage Loan Trust 2019 E, Mortgage Backed Securities, Series 2019 E, U.S. Bank National Association, as Indenture Trustee Plaintiff vs. Melvyn Hirsch, et al Defendant

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                                Filing # 101831900 E-Filed 01/17/2020 11:16:07 AM

IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA

BANK OF AMERICA, N.A. GENERAL JURISDICTION DIVISION
CASE NO.: CACE 19-011787

Plaintiff,

Vs.

MELVYN HIRSCH, DOROTHY HIRSCH A/K/A.
DOROTHY D. HIRSCH, ORIOLE GOLF AND
TENNIS CLUB CONDOMINIUM TWO
ASSOCIATION, INC. THE UNKNOWN
TENANT #1 N/K/A SOLFEMERI PATINO

Defendants.
/

DEFENDANT ORIOLE GOLF AND TENNIS CLUB CONDOMINIUM TWO

ASSOCIATION, INC’S ANSWER TO PLAINTIFF’S VERIFIED AMENDED
COMPLAINT FOR FORECLOSURE OF MORTGAGE

Defendant, Oriole Golf and Tennis Club Condominium Two Association, Inc.
(“Oriole”) by and through undersigned counsel files its Answer to Plaintiff's Verified Complaint

for Foreclosure of Mortgage and states as follows:

I. ANSWER
Jurisdiction and Venue
1. Oriole admits the allegations set forth in paragraph 1 of the Complaint.
2. Oriole admits the allegations set forth in paragraph 2 of the Complaint.
3. Oriole admits the allegations set forth in paragraph 3 of the Complaint.

General Allegations

*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/17/2020 11:16:06 AM.****CASE NO.: CACE 19-011787

4. Oriole is without knowledge as to the allegations set forth in paragraph 4 of the

Complaint.

5. Oriole is without knowledge as to the allegations set forth in paragraph 5

Complaint.

6. Oriole is without knowledge as to the allegations set forth in paragraph 6

Complaint.

7. Oriole admits the allegations set forth in paragraph 7 of the Complaint.

8. Oriole
Complaint.
9. Oriole

Complaint.

10. Oriole i

Complaint.

11. Oriole i

Complaint.

12. Oriole i

Complaint.

13. Oriole i

Complaint.

is

a

without knowledge

without knowledge

without knowledge

without knowledge

without knowledge

without knowledge

as to the allegations set forth in paragraph 8

as to the allegations set forth in paragraph 9

as to the allegations set forth in paragraph 10

as to the allegations set forth in paragraph 11

as to the allegations set forth in paragraph 12

as to the allegations set forth in paragraph 13

of the

of the

of the

of the

of the

of the

of the

of the

14. Oriole admits in part the allegations set forth in paragraph 14 of the Compliant, but

denies the allegations to the extent that they state that Oriole’s interest in the subject property is

subject, subordinate, and inferior to the lien of Plaintiff's mortgage.CASE NO.: CACE 19-011787

15. Oriole is without knowledge as to the allegations set forth in paragraph 15 of the

Complaint.

I. Mortgage Foreclosure
16. Oriole re-alleges its answers as set forth above in paragraphs 1-15 as if fully set forth
herein.
17. Oriole is without knowledge as to the allegations set forth in paragraph 17 of the
Complaint.

WHEREFORE, Oriole respectfully requests that the Court (i) dismiss the Complaint
with prejudice, (ii) award Oriole costs and attorneys’ fees incurred in relation to this action, and
(iii) grant such other and further relief to Oriole as the Court deems just and proper.

II. Action on a Promissory Note
18. Oriole re-alleges its answers as set forth above in paragraphs 1-15 as if fully set forth
herein.
19. Oriole is without knowledge as to the allegations set forth in paragraph 19 of the
Complaint.
20. Oriole is without knowledge as to the allegations set forth in paragraph 20 of the
Complaint.

WHEREFORE, Oriole respectfully requests that the Court (i) dismiss the Complaint

with prejudice, (ii) award Oriole costs and attorneys’ fees incurred in relation to this action, and

(iii) grant such other and further relief to Oriole as the Court deems just and proper.CASE NO.: CACE 19-011787

CERTIFICATE OF SERVICE

1 HEREBY CERTIFY that on this 17" Day of January, 2020 a true and correct copy of the
foregoing has been electronically filed with the Clerk of the Court utilizing the Florida Courts E-Filing

Portal and that the forgoing document has been served via e-mail upon: The Lamchick Law Group, P.A.

Attn. Travis Bailey, Esq. at secretary@lamchick.com & assistant@lamchick.com

RESPECTFULLY SUBMITTED,
Rossman Legal

Attorneys for Plaintiff

6840 Griffin Road

Davie, FL 33317

Tel: (954) 440-0908

Primary Email:Chelsea@rossmanlegal.com

Secondary Email: jay@rossmanlegal.com

By:__/s/ Jay R. Tome, Esq.
JAY R. TOME, ESQUIRE
Florida Bar No. 769400