On December 31, 2015 a
Answer
was filed
involving a dispute between
Wells Fargo Financial System Florida Inc,
and
Karanda Village V Condominium Association Inc,
Modlin, Peter M,
Modlin, Vivian,
Township Community Master Association Inc,
Wells Fargo Bank Na,
for Real Prop Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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Filing # 36952475 E-Filed 01/25/2016 02:37:08 PM
IN THE CIRCUIT COURT OF THE 17"
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 16-000020 CACE (11)
WELLS FARGO FINANCIAL SYSTEM
FLORIDA, INC.,
Plaintiff,
vs.
VIVAN MODLIN a/k/a VIVIAN
LEFF, et al.,
Defendants.
DEFENDANT, THE TOWNSHIP COMMUNITY
MASTER ASSOCIATION, INC.'s, ANSWER
The Defendant, THE TOWNSHIP COMMUNITY MASTER ASSOCIATION, INC.
(hereinafter referred to as “TCMA”), by and through its undersigned counsel, files this its Answer
to the Verified Complaint to Foreclose Mortgage filed herein and says:
1. Without knowledge and therefore denied
2. Without knowledge and therefore denied.
3. Without knowledge and therefore denied.
4. Without knowledge and therefore denied.
5. Without knowledge and therefore denied.
6. Without knowledge and therefore denied.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/25/2016 2:37:08 PM.****7. Without knowledge and therefore denied.
8. Without knowledge and therefore denied.
9. Without knowledge and therefore denied.
10. Without knowledge and therefore denied.
11. Without knowledge and therefore denied.
12. Without knowledge and therefore denied.
13. Admitted.
14. Without knowledge and therefore denied.
15. Without knowledge and therefore denied.
16. Without knowledge and therefore denied.
WHEREFORE, Defendant, THE TOWNSHIP COMMUNITY MASTER ASSOCIATION,
INC., prays that this Court require strict proof as to the allegations contained in the Complaint, and
that the Court take jurisdiction of the parties hereto for the purposes of determining the priority of
the claimants to the proceeds of any foreclosure sale ordered herein by the Court and that said
funds that are received from any foreclosure sale be disbursed in accordance therewith. Defendant
also demands an award of attorney's fees and costs, pursuant to the recorded Declaration of
Condominium and Sections 57.105 and 718, Florida Statutes.
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by E-
ole
Mail this_25 day of January, 2016 to Heather Lynn Griffiths, Esq., Phelan Hallinan Diamond &Jones, PLLC, 2727 W. Cypress Creek Road, Ft. Lauderdale, FL 33309,
fl.service@phelanhallinan.com.
Martin & Bennis, P.A.
Attorneys for Defendant/TCMA
319 S.E. 14th Street
Ft. Lauderdale, FL 33316
Phone: (954) 524-5331
Fax: (954) 522-8610
E-mail: bob@martinandbennis.com
BY:
ROBERT C. MARTIN
Fla. Bar No. 326615
Document Filed Date
January 25, 2016
Case Filing Date
December 31, 2015
Category
Real Prop Homestead Res Fore - >$50K - <$250,000
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Filing # 36952475 E-Filed 01/25/2016 02:37:08 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 16-000020 CACE (11) WELLS FARGO FINANCIAL SYSTEM FLORIDA, INC., Plaintiff, vs. VIVAN MODLIN a/k/a VIVIAN LEFF, et al., Defendants. DEFENDANT, THE TOWNSHIP COMMUNITY MASTER ASSOCIATION, INC.'s, ANSWER The Defendant, THE TOWNSHIP COMMUNITY MASTER ASSOCIATION, INC. (hereinafter referred to as “TCMA”), by and through its undersigned counsel, files this its Answer to the Verified Complaint to Foreclose Mortgage filed herein and says: 1. Without knowledge and therefore denied 2. Without knowledge and therefore denied. 3. Without knowledge and therefore denied. 4. Without knowledge and therefore denied. 5. Without knowledge and therefore denied. 6. Without knowledge and therefore denied. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 1/25/2016 2:37:08 PM.****7. Without knowledge and therefore denied. 8. Without knowledge and therefore denied. 9. Without knowledge and therefore denied. 10. Without knowledge and therefore denied. 11. Without knowledge and therefore denied. 12. Without knowledge and therefore denied. 13. Admitted. 14. Without knowledge and therefore denied. 15. Without knowledge and therefore denied. 16. Without knowledge and therefore denied. WHEREFORE, Defendant, THE TOWNSHIP COMMUNITY MASTER ASSOCIATION, INC., prays that this Court require strict proof as to the allegations contained in the Complaint, and that the Court take jurisdiction of the parties hereto for the purposes of determining the priority of the claimants to the proceeds of any foreclosure sale ordered herein by the Court and that said funds that are received from any foreclosure sale be disbursed in accordance therewith. Defendant also demands an award of attorney's fees and costs, pursuant to the recorded Declaration of Condominium and Sections 57.105 and 718, Florida Statutes. I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by E- ole Mail this_25 day of January, 2016 to Heather Lynn Griffiths, Esq., Phelan Hallinan Diamond &Jones, PLLC, 2727 W. Cypress Creek Road, Ft. Lauderdale, FL 33309, fl.service@phelanhallinan.com. Martin & Bennis, P.A. Attorneys for Defendant/TCMA 319 S.E. 14th Street Ft. Lauderdale, FL 33316 Phone: (954) 524-5331 Fax: (954) 522-8610 E-mail: bob@martinandbennis.com BY: ROBERT C. MARTIN Fla. Bar No. 326615