On March 14, 2013 a
Answer
was filed
involving a dispute between
Jpmorgan Chase Bank Na,
and
Apple Creek Rec & Mgmt Company,
Apple Creek Unit Two Inc,
Capital Bank,
Suckra, Lesa-Gaye Lorraine,
Suckra, Romark,
for Real Prop Non-Homestead Res Fore - >$50K - <$250,000
in the District Court of Broward County.
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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/2/2013 2:12:16 PM.****
Electronically Filed 04/02/2013 02:12:17 PM ET
IN THE CIRCUIT COURT OF THE 174
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. CACE 13-006873 (11)
JPMORGAN CHASE BANK, etc.
Plaintiff,
vs.
LESA-GAYE LORRAINE SUCKRA, et al.,
Defendants.
/
ANSWER OF APPLE CREEK UNIT TWO, INC., TO VERIFIED COMPLAINT
COMES NOW Defendant, APPLE CREEK UNIT TWO, INC., by and through
their undersigned attorneys, and hereby files their Answer to the Verified Complaint and
states:
1. That the Defendant is without knowledge as to Paragraphs 1, 2, 3, 4, 5, 6,
7,9, 10, 11(a), 11(b) 11(c), 11(d), 11(f) and 11(g) and demands strict proof thereof.
2. That the Defendant admits Paragraph 8.
3. That the Defendant admits Paragraph 11, but denies that its interest is
secondary, junior, inferior and subject to the prior claim of Plaintiff and demands strict
proof thereof.
WHEREFORE, Defendant, APPLE CREEK UNIT TWO, INC., hereby prays that
this Court take jurisdiction over the parties and the subject matter of this cause,
determine the extent and priority of each of the parties’ interest in and to the real
property which is the subject of this foreclosure action, and should a public foreclosure
sale be held, that the proceeds of said foreclosure sale be applied to satisfy the interest
of each of these parties to the extent and in the order of priority of said interest.CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy of the foregoing was emailed to
CHRISTOPHER R. KASPER, ESQ., Aldridge Connors, LLP, servicemail@aclawllp.com
on April 2, 2013.
FRANK, WEINBERG & BLACK, P.L.
Attorneys for Apple Creek Unit Two, Inc.
7805 S.W. 6” Court
Plantation, Florida 33324
Telephone: (954) 474-8000
Facsimile: (954) 474-9850
BY_/s/ Jacqueline A. Grady
JACQUELINE A. GRADY
jgrady@fwblaw.net
Fla. Bar #635871
Document Filed Date
April 02, 2013
Case Filing Date
March 14, 2013
Category
Real Prop Non-Homestead Res Fore - >$50K - <$250,000
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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 4/2/2013 2:12:16 PM.**** Electronically Filed 04/02/2013 02:12:17 PM ET IN THE CIRCUIT COURT OF THE 174 JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE 13-006873 (11) JPMORGAN CHASE BANK, etc. Plaintiff, vs. LESA-GAYE LORRAINE SUCKRA, et al., Defendants. / ANSWER OF APPLE CREEK UNIT TWO, INC., TO VERIFIED COMPLAINT COMES NOW Defendant, APPLE CREEK UNIT TWO, INC., by and through their undersigned attorneys, and hereby files their Answer to the Verified Complaint and states: 1. That the Defendant is without knowledge as to Paragraphs 1, 2, 3, 4, 5, 6, 7,9, 10, 11(a), 11(b) 11(c), 11(d), 11(f) and 11(g) and demands strict proof thereof. 2. That the Defendant admits Paragraph 8. 3. That the Defendant admits Paragraph 11, but denies that its interest is secondary, junior, inferior and subject to the prior claim of Plaintiff and demands strict proof thereof. WHEREFORE, Defendant, APPLE CREEK UNIT TWO, INC., hereby prays that this Court take jurisdiction over the parties and the subject matter of this cause, determine the extent and priority of each of the parties’ interest in and to the real property which is the subject of this foreclosure action, and should a public foreclosure sale be held, that the proceeds of said foreclosure sale be applied to satisfy the interest of each of these parties to the extent and in the order of priority of said interest.CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy of the foregoing was emailed to CHRISTOPHER R. KASPER, ESQ., Aldridge Connors, LLP, servicemail@aclawllp.com on April 2, 2013. FRANK, WEINBERG & BLACK, P.L. Attorneys for Apple Creek Unit Two, Inc. 7805 S.W. 6” Court Plantation, Florida 33324 Telephone: (954) 474-8000 Facsimile: (954) 474-9850 BY_/s/ Jacqueline A. Grady JACQUELINE A. GRADY jgrady@fwblaw.net Fla. Bar #635871