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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/29/2013 9:10:18 PM.****
Electronically Filed 07/29/2013 09:10:20 PM ET
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, STATE OF FLORIDA
CIVIL DIVISION
OCWEN LOAN SERVICING, LLC,
CASE NO.: CACE12003293
Plaintiff,
vs.
JIHAD K. EL EID, LINA R. EL EID
Defendant.
REQUEST FOR PRODUCTION OF DOCUMENT
COMES NOW the Defendant, JIHAD K EL EID and LINA R EL EID, by and through the
undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, and files and
serves their First Request for Production to Plaintiff and requests Plaintiff to produce within
thirty (30) days of the date of this Request, the following documents to be sent to: Jacob Stone,
Esq. 805 Sebastian Blvd #3, Sebastian, FL 32958.
“Document” as utilized herein is to be construed, understood, and intended to mean the original
of any and all books, papers, records, logs, ledgers, telefaxes, telexes, microfilm, microfiche,
memoranda (whether handwritten, typed, computer-generated, or otherwise), books of account,
logbooks, data banks, data bases, and any other manner and/or means of data and/or information
storage, including but not limited to computer discs, tape backup or storage, or otherwise.
If the original of any requested document is not available, the specific reason(s) for such
non-availability shall be specifically stated in your response. Production of the originaldocuments is appropriate under the best evidence rule and case law thereunder. Fla.Stat. sec.
90.901, 90.952, 90.953; Sun Bank of St. Lucie County v. Oliver, 403 So.2d 583 (Fla. 4th DCA
1981).
IF ANY CLAIM OF PRIVILEGE IS MADE AS TO ALL OR ANY PART OF ANY OF THE
CATEGORICAL REQUESTS HEREINBELOW, YOU ARE TO SERVE A PRIVILEGE
LOG WITH YOUR RESPONSE TO THIS REQUEST FOR PRODUCTION, WHICH
PRIVILEGE LOG SHALL INCLUDE A GENERIC DESCRIPTION OF THE DOCUMENT,
THE AUTHOR THEREOF, THE INTENDED RECIPIENT THEREOF, THE DATE
THEREOF, AND THE IDENTIFICATIONOF ANY PRIVILEGE(S) CLAIMED AS TO THE
DOCUMENT.
Documents to be produced:
1. All Assignments, Allonges, and the like which purport to assign any interest in any mortgage
instrument or note of any of the Defendants to any person or party.
2. All documents setting forth any servicing agreement between the Plaintiff and any entity with
reference to the mortgage loans of the Defendants.
3. All Pooling and Service Agreements, Custodial Agreements, Deposit
Agreements, Master Purchasing Agreements, Issuer Agreements, Commitment to Guarantee
Agreements, Release of Document Agreements, Master Agreements for Servicer’s Principal and
Interest Custodial Account, Servicer’s Escrow Custodial Account Agreements, Release of
Interest Agreements, or Trustee Agreements relating to the mortgages loan of the Defendants.
4. All documents setting forth the entire chain of title to the mortgage instruments and notes of
the Defendants from the original lender to the present true owner and holder of the note and
mortgage instruments (pursuant to 15 USC (TILA) sec. 1641(f)(2)).
5. The entire loan underwriting file for each of the Defendants’ mortgage loans, including all
documents setting forth mortgage loans for which the Defendants qualified and all inquiries
made to any lender as to mortgage loans available to the Defendants.
6. All documents setting forth verification of all fees paid or assessed on the HUD-1.
7. All documents setting forth any authority of either of the Plaintiffs or any agent thereof to
institute any foreclosure threat or action against any of the Defendants.
8. All policies of insurance, including but not limited to private mortgage insurance, insurance in
favor of any trustee or loan trust, LPMI policies, NIM policies, UCC Eagle 9 mezzanine policies,
ISDA swap policies, master and bulk supplemental policies, mortgagee title policies, or any other
insurance which provides benefits to either of the Plaintiffs or any party in privity with either ofthe Plaintiffs or the original lender or successor thereto or securitized trust upon default by the
borrower in connection with the Defendants’ mortgage loans.
9. All documents setting forth any claims made against any policy of insurance the subject of
request number “8.” above.
10. All documents setting forth any payments made or received in connection with any claim the
subject of request number “9.” above.
11. All documents setting forth any denial or reservation of rights as to any claim made in
connection with any policy of insurance the subject of request number “8.” above.
12. All documents demonstrating any funding of any of the Defendants’ mortgage loan the
subject of this action by any certificated or uncertificated security.
13. All documents concerning any consideration exchanged between any persons or parties in
connection with the assignment or sale of any part of, or right under, or right incident to any of
the Defendants’ mortgage loans (e.g. assignment or sale of mortgage, assignment or sale of note,
assignment or sale of servicing rights, assignment or sale of right to income stream from
borrower payments, assignment to a mortgage pool, assignment to any SIV, CMO, CDO, MBS,
or CDS, [as defined herein infra], and the like).
14. All credit default swap partner agreements and/or ISDA swap agreements.
15. All documents setting forth all information contained within any mortgage servicing or
accounting computer systems, including but not limited to Alltel or Fidelity CPI systems or any
other software, concerning the servicing or sub-servicing of the Defendants’ mortgage loans from
inception of the account to the present.
16. All documents identifying any descriptions or legends of all codes utilized within any
mortgage servicing or accounting system identified within your response to request number “15.”
above.
17. All documents evidencing all payments made by the Defendants or any third party on or
toward their loan obligations at any time.
18. All documents setting forth any credits applied against any balance due on the Defendants’
mortgage loans at any time, including amount of credit, date credit applied, source of credit, and
obligation to which credit was applied (e.g. principal, interest, late fees, etc.)
19. All documents setting forth the disposition of all payments made by the Defendants or any
third party in connection with the Defendants’ mortgage loans, including but not limited to
documentation setting forth amounts assigned to or credited against principal, interest, insurance
escrows or payments, tax escrows or payments, late fees, or any other charges.
20. All documents setting forth the treatment of all taxes relating to the Defendants’ mortgage
loans, including but not limited to establishment and maintenance of tax escrows, payment oftaxes, refund of excess escrows, source of funds for tax escrows and payments, and the like.
21. All escrow analyses in reference to the Defendants’ mortgage loans from inception of the
account to the present.
22. All documents evidencing any agreement between the original lender, or either of the
Plaintiffs, or any other person or party and any appraisal company, appraiser, or mortgage broker
relating to the Defendants’ mortgage loans or the real property subject to the Defendants’
mortgage loans.
23. All documents evidencing any agreement between the original lender and any person or party
relating to the servicing, in any respect, of the Defendants’ mortgage loans.
24. All documents evidencing any agreement between Plaintiffs and any person or party relating
to the servicing, in any respect, of the Defendants’ mortgage loans.
25. All documents comprising invoices, bills, or statements for any charges in connection with
the Defendants’ mortgage loans, including but not limited to appraisals, inspections, BPOs
(Broker Price Opinions), attorneys’ fees, accounting fees and the like whether or not identified
on the HUD-1 Settlement Statement.
26. All documents comprising the account servicing records in connection with the Defendants’
mortgage loans relating to calculation of interest, interest rate adjustments, ARM audits, and the
like from the inception of the account to the present.
27. All documents relating to any suspense or unapplied account transactions in connection with
the Defendants’ mortgage loans from inception of the account to the present.
28. All documents setting forth the assessment of any late fees in connection with the
Defendants’ mortgage loans and the treatment thereof (e.g. as liquidated damages, interest, or
otherwise).
29. All appraisals and property inspections concerning the Defendants’ real property subject to
the mortgage loans claimed to be owned by any of the Plaintiff.
30. All appraisals, evaluations, broker assessments, or other valuations as to the Defendants’
mortgage loans.
31. All documents setting forth any forced-placed insurance on the real property subject to the
Defendants’ mortgage loans.
32. All documents setting forth any notice to any of the Defendants that any person or party
intended to force-place insurance coverage on the Defendants’ real property subject to the
mortgage loans claimed to be owned by any of the Plaintiff.33. All documents signed by any of the Defendants authorizing the assessment, charge, or
collection of any forced-placed insurance coverage.
34. All documents evidencing the recording of any assignment of the note or mortgage
instrument as to any of the Defendants’ mortgage loans claimed to be owned by any of the
Plaintiff.
35. All documents setting forth the present physical location of the original mortgage instrument
and the original note for any of the Defendants’ mortgage loans claimed to be owned by any of
the Plaintiff.
36. All documents setting forth the name, address, and telephone number of the physical
custodian of the original note and original mortgage instrument for any of the Defendants’
mortgage loans claimed to be owned by any of the Plaintiff.
37. All documents setting forth the assignment of either the mortgage instrument or note for any
of the Defendants’ mortgage loans, which are claimed to be owned by any of the Plaintiff, to any
particular Specialized Investment Vehicle (SIV), Collateralized Mortgage Obligation (CMO),
Collateralized Debt Obligation (CDO), series of mortgage-backed securities or certificates
(MBS), or collateral default swap (CDS).
38. All documents setting forth the full name, current address, and telephone number of each
holder of or investor in any SIV, CMO, CDO, MBS, or CDS which is collateralized in whole or
in part by any of the Defendants’ mortgage loans or any right incident thereto or thereunder.
39. All documents which identify the full name, current address, and telephone number of all
persons who authorized the filing of any foreclosure action or threat of any foreclosure against
any of the Defendants.
40. All documents demonstrating the granting of any authority of any kind whatsoever from the
original lender to MERS in any respect whatsoever.
41. All documents related to any trust (e.g. trust indenture, trust document, etc.) or trustee (¢.g.
appointment and powers of trustee for trust) of any trust created incident to the securitization of
any of the Defendants’ mortgage loans.
42. All documents demonstrating the compliance of the REMIC into which any of the
Defendants’ mortgage loans were assigned with Internal Revenue Code section 860.
43. All documents demonstrating compliance by the REMIC or any Trustee with all REMIC
qualification guidelines.
44. All documents evidencing the receipt and application of any monies received from or as a
result of the Federal Trouble Assets Recovery Program (TARP) including but not limited to any
request for such funds based in part on a default of any of the Defendants’ mortgage loans and
application of any such funds toward any such default.45. All documents which provide any authority of MERS or any other person or entity to transfer
a Note and Mortgage instrument into a securitized mortgage loan trust after the closing date
thereof.
46. All Governing Documents, memoranda, or other writings setting forth all terms and
conditions between any mortgage loan servicer and any alleged owner of any of the Defendants’
promissory notes tied to a mortgage instrument, including notification of claims.
47. The title page to each of the Defendants’ mortgage loans.
48. IRS Form 1099-OID for each of the Defendants’ mortgage loans.
49. IRS Form 1066 with accompanying Schedule Q for each of the Defendants’ mortgage loans.
50. All servicing contracts between any insurance tracker and any loan servicer as to the
Defendants’ mortgage loans and/or any securitized mortgage loan trust into which any of the
Defendants’ mortgage loans were assigned or placed, including all addenda and schedules thereto
or identified therein including but not limited to Service Level Agreements (SLA), Return To
Lender (RTL) documents, and any listing of Unable To Locate (UTL) Documents.
51. All documents identifying the Operations Account Manager (OAM) for the specific
account(s) related to the Defendants’ mortgage loans.
52. All documents conceming or relating to any reports of transactions between financial and
foreclosure-related systems as to the Defendants’ mortgage loans including but not limited to
reports provided by Fidelity systems and/or tracked in web-based filing cabinets (including but
not limited to Balboa_IT_CCS) and in any system including but not limited to AXSPoint,
COOL, or otherwise.
53. All reports of any experts, accountants, and the like upon which any of the Plaintiff intends to
rely in the trial of this cause or at any hearing, and all documents upon which Plaintiffs intend to
rely or which Plaintiffs intend to introduce into evidence in support of any Motion or at the trial
of this cause.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been
furnished by E-Mail to all parties on the attached Service List on July 29" 2013.
By:
SERVICE LIST
Jacob Stone, Esq.
Diesenhof & Stone
805 Sebastian Blvd #3
Sebastian, FL 32958
Email:
(888) 369-7774
Counsel for Defendants,
EL EID
Jacob M. Resnick, Esq.
McCalla Raymer, LLC
225 E. Robinson St. Suite 660
Orlando, FL 32801
Phone: (407) 674-1850
Email: MRService@mecallaraymer.co
Attorneys for the Plaintiff
Diesenhof & Stone
Counsel for the Defendant EL EID
805 Sebastian Blvd #3
Sebastian, FL 32958
diesenhofandstone@gmail.com
(888) 369-7774
/S/ Jacob Stone
Jacob Stone, Esquire
Florida Bar Number # 0084610
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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/29/2013 9:10:18 PM.**** Electronically Filed 07/29/2013 09:10:20 PM ET IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, STATE OF FLORIDA CIVIL DIVISION OCWEN LOAN SERVICING, LLC, CASE NO.: CACE12003293 Plaintiff, vs. JIHAD K. EL EID, LINA R. EL EID Defendant. REQUEST FOR PRODUCTION OF DOCUMENT COMES NOW the Defendant, JIHAD K EL EID and LINA R EL EID, by and through the undersigned counsel, pursuant to Rule 1.350, Florida Rules of Civil Procedure, and files and serves their First Request for Production to Plaintiff and requests Plaintiff to produce within thirty (30) days of the date of this Request, the following documents to be sent to: Jacob Stone, Esq. 805 Sebastian Blvd #3, Sebastian, FL 32958. “Document” as utilized herein is to be construed, understood, and intended to mean the original of any and all books, papers, records, logs, ledgers, telefaxes, telexes, microfilm, microfiche, memoranda (whether handwritten, typed, computer-generated, or otherwise), books of account, logbooks, data banks, data bases, and any other manner and/or means of data and/or information storage, including but not limited to computer discs, tape backup or storage, or otherwise. If the original of any requested document is not available, the specific reason(s) for such non-availability shall be specifically stated in your response. Production of the originaldocuments is appropriate under the best evidence rule and case law thereunder. Fla.Stat. sec. 90.901, 90.952, 90.953; Sun Bank of St. Lucie County v. Oliver, 403 So.2d 583 (Fla. 4th DCA 1981). IF ANY CLAIM OF PRIVILEGE IS MADE AS TO ALL OR ANY PART OF ANY OF THE CATEGORICAL REQUESTS HEREINBELOW, YOU ARE TO SERVE A PRIVILEGE LOG WITH YOUR RESPONSE TO THIS REQUEST FOR PRODUCTION, WHICH PRIVILEGE LOG SHALL INCLUDE A GENERIC DESCRIPTION OF THE DOCUMENT, THE AUTHOR THEREOF, THE INTENDED RECIPIENT THEREOF, THE DATE THEREOF, AND THE IDENTIFICATIONOF ANY PRIVILEGE(S) CLAIMED AS TO THE DOCUMENT. Documents to be produced: 1. All Assignments, Allonges, and the like which purport to assign any interest in any mortgage instrument or note of any of the Defendants to any person or party. 2. All documents setting forth any servicing agreement between the Plaintiff and any entity with reference to the mortgage loans of the Defendants. 3. All Pooling and Service Agreements, Custodial Agreements, Deposit Agreements, Master Purchasing Agreements, Issuer Agreements, Commitment to Guarantee Agreements, Release of Document Agreements, Master Agreements for Servicer’s Principal and Interest Custodial Account, Servicer’s Escrow Custodial Account Agreements, Release of Interest Agreements, or Trustee Agreements relating to the mortgages loan of the Defendants. 4. All documents setting forth the entire chain of title to the mortgage instruments and notes of the Defendants from the original lender to the present true owner and holder of the note and mortgage instruments (pursuant to 15 USC (TILA) sec. 1641(f)(2)). 5. The entire loan underwriting file for each of the Defendants’ mortgage loans, including all documents setting forth mortgage loans for which the Defendants qualified and all inquiries made to any lender as to mortgage loans available to the Defendants. 6. All documents setting forth verification of all fees paid or assessed on the HUD-1. 7. All documents setting forth any authority of either of the Plaintiffs or any agent thereof to institute any foreclosure threat or action against any of the Defendants. 8. All policies of insurance, including but not limited to private mortgage insurance, insurance in favor of any trustee or loan trust, LPMI policies, NIM policies, UCC Eagle 9 mezzanine policies, ISDA swap policies, master and bulk supplemental policies, mortgagee title policies, or any other insurance which provides benefits to either of the Plaintiffs or any party in privity with either ofthe Plaintiffs or the original lender or successor thereto or securitized trust upon default by the borrower in connection with the Defendants’ mortgage loans. 9. All documents setting forth any claims made against any policy of insurance the subject of request number “8.” above. 10. All documents setting forth any payments made or received in connection with any claim the subject of request number “9.” above. 11. All documents setting forth any denial or reservation of rights as to any claim made in connection with any policy of insurance the subject of request number “8.” above. 12. All documents demonstrating any funding of any of the Defendants’ mortgage loan the subject of this action by any certificated or uncertificated security. 13. All documents concerning any consideration exchanged between any persons or parties in connection with the assignment or sale of any part of, or right under, or right incident to any of the Defendants’ mortgage loans (e.g. assignment or sale of mortgage, assignment or sale of note, assignment or sale of servicing rights, assignment or sale of right to income stream from borrower payments, assignment to a mortgage pool, assignment to any SIV, CMO, CDO, MBS, or CDS, [as defined herein infra], and the like). 14. All credit default swap partner agreements and/or ISDA swap agreements. 15. All documents setting forth all information contained within any mortgage servicing or accounting computer systems, including but not limited to Alltel or Fidelity CPI systems or any other software, concerning the servicing or sub-servicing of the Defendants’ mortgage loans from inception of the account to the present. 16. All documents identifying any descriptions or legends of all codes utilized within any mortgage servicing or accounting system identified within your response to request number “15.” above. 17. All documents evidencing all payments made by the Defendants or any third party on or toward their loan obligations at any time. 18. All documents setting forth any credits applied against any balance due on the Defendants’ mortgage loans at any time, including amount of credit, date credit applied, source of credit, and obligation to which credit was applied (e.g. principal, interest, late fees, etc.) 19. All documents setting forth the disposition of all payments made by the Defendants or any third party in connection with the Defendants’ mortgage loans, including but not limited to documentation setting forth amounts assigned to or credited against principal, interest, insurance escrows or payments, tax escrows or payments, late fees, or any other charges. 20. All documents setting forth the treatment of all taxes relating to the Defendants’ mortgage loans, including but not limited to establishment and maintenance of tax escrows, payment oftaxes, refund of excess escrows, source of funds for tax escrows and payments, and the like. 21. All escrow analyses in reference to the Defendants’ mortgage loans from inception of the account to the present. 22. All documents evidencing any agreement between the original lender, or either of the Plaintiffs, or any other person or party and any appraisal company, appraiser, or mortgage broker relating to the Defendants’ mortgage loans or the real property subject to the Defendants’ mortgage loans. 23. All documents evidencing any agreement between the original lender and any person or party relating to the servicing, in any respect, of the Defendants’ mortgage loans. 24. All documents evidencing any agreement between Plaintiffs and any person or party relating to the servicing, in any respect, of the Defendants’ mortgage loans. 25. All documents comprising invoices, bills, or statements for any charges in connection with the Defendants’ mortgage loans, including but not limited to appraisals, inspections, BPOs (Broker Price Opinions), attorneys’ fees, accounting fees and the like whether or not identified on the HUD-1 Settlement Statement. 26. All documents comprising the account servicing records in connection with the Defendants’ mortgage loans relating to calculation of interest, interest rate adjustments, ARM audits, and the like from the inception of the account to the present. 27. All documents relating to any suspense or unapplied account transactions in connection with the Defendants’ mortgage loans from inception of the account to the present. 28. All documents setting forth the assessment of any late fees in connection with the Defendants’ mortgage loans and the treatment thereof (e.g. as liquidated damages, interest, or otherwise). 29. All appraisals and property inspections concerning the Defendants’ real property subject to the mortgage loans claimed to be owned by any of the Plaintiff. 30. All appraisals, evaluations, broker assessments, or other valuations as to the Defendants’ mortgage loans. 31. All documents setting forth any forced-placed insurance on the real property subject to the Defendants’ mortgage loans. 32. All documents setting forth any notice to any of the Defendants that any person or party intended to force-place insurance coverage on the Defendants’ real property subject to the mortgage loans claimed to be owned by any of the Plaintiff.33. All documents signed by any of the Defendants authorizing the assessment, charge, or collection of any forced-placed insurance coverage. 34. All documents evidencing the recording of any assignment of the note or mortgage instrument as to any of the Defendants’ mortgage loans claimed to be owned by any of the Plaintiff. 35. All documents setting forth the present physical location of the original mortgage instrument and the original note for any of the Defendants’ mortgage loans claimed to be owned by any of the Plaintiff. 36. All documents setting forth the name, address, and telephone number of the physical custodian of the original note and original mortgage instrument for any of the Defendants’ mortgage loans claimed to be owned by any of the Plaintiff. 37. All documents setting forth the assignment of either the mortgage instrument or note for any of the Defendants’ mortgage loans, which are claimed to be owned by any of the Plaintiff, to any particular Specialized Investment Vehicle (SIV), Collateralized Mortgage Obligation (CMO), Collateralized Debt Obligation (CDO), series of mortgage-backed securities or certificates (MBS), or collateral default swap (CDS). 38. All documents setting forth the full name, current address, and telephone number of each holder of or investor in any SIV, CMO, CDO, MBS, or CDS which is collateralized in whole or in part by any of the Defendants’ mortgage loans or any right incident thereto or thereunder. 39. All documents which identify the full name, current address, and telephone number of all persons who authorized the filing of any foreclosure action or threat of any foreclosure against any of the Defendants. 40. All documents demonstrating the granting of any authority of any kind whatsoever from the original lender to MERS in any respect whatsoever. 41. All documents related to any trust (e.g. trust indenture, trust document, etc.) or trustee (¢.g. appointment and powers of trustee for trust) of any trust created incident to the securitization of any of the Defendants’ mortgage loans. 42. All documents demonstrating the compliance of the REMIC into which any of the Defendants’ mortgage loans were assigned with Internal Revenue Code section 860. 43. All documents demonstrating compliance by the REMIC or any Trustee with all REMIC qualification guidelines. 44. All documents evidencing the receipt and application of any monies received from or as a result of the Federal Trouble Assets Recovery Program (TARP) including but not limited to any request for such funds based in part on a default of any of the Defendants’ mortgage loans and application of any such funds toward any such default.45. All documents which provide any authority of MERS or any other person or entity to transfer a Note and Mortgage instrument into a securitized mortgage loan trust after the closing date thereof. 46. All Governing Documents, memoranda, or other writings setting forth all terms and conditions between any mortgage loan servicer and any alleged owner of any of the Defendants’ promissory notes tied to a mortgage instrument, including notification of claims. 47. The title page to each of the Defendants’ mortgage loans. 48. IRS Form 1099-OID for each of the Defendants’ mortgage loans. 49. IRS Form 1066 with accompanying Schedule Q for each of the Defendants’ mortgage loans. 50. All servicing contracts between any insurance tracker and any loan servicer as to the Defendants’ mortgage loans and/or any securitized mortgage loan trust into which any of the Defendants’ mortgage loans were assigned or placed, including all addenda and schedules thereto or identified therein including but not limited to Service Level Agreements (SLA), Return To Lender (RTL) documents, and any listing of Unable To Locate (UTL) Documents. 51. All documents identifying the Operations Account Manager (OAM) for the specific account(s) related to the Defendants’ mortgage loans. 52. All documents conceming or relating to any reports of transactions between financial and foreclosure-related systems as to the Defendants’ mortgage loans including but not limited to reports provided by Fidelity systems and/or tracked in web-based filing cabinets (including but not limited to Balboa_IT_CCS) and in any system including but not limited to AXSPoint, COOL, or otherwise. 53. All reports of any experts, accountants, and the like upon which any of the Plaintiff intends to rely in the trial of this cause or at any hearing, and all documents upon which Plaintiffs intend to rely or which Plaintiffs intend to introduce into evidence in support of any Motion or at the trial of this cause.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing has been furnished by E-Mail to all parties on the attached Service List on July 29" 2013. By: SERVICE LIST Jacob Stone, Esq. Diesenhof & Stone 805 Sebastian Blvd #3 Sebastian, FL 32958 Email: (888) 369-7774 Counsel for Defendants, EL EID Jacob M. Resnick, Esq. McCalla Raymer, LLC 225 E. Robinson St. Suite 660 Orlando, FL 32801 Phone: (407) 674-1850 Email: MRService@mecallaraymer.co Attorneys for the Plaintiff Diesenhof & Stone Counsel for the Defendant EL EID 805 Sebastian Blvd #3 Sebastian, FL 32958 diesenhofandstone@gmail.com (888) 369-7774 /S/ Jacob Stone Jacob Stone, Esquire Florida Bar Number # 0084610