arrow left
arrow right
  • Wells Fargo Bank NA Plaintiff vs. Shalee M Lindey Defendant Contract and Indebtedness document preview
  • Wells Fargo Bank NA Plaintiff vs. Shalee M Lindey Defendant Contract and Indebtedness document preview
  • Wells Fargo Bank NA Plaintiff vs. Shalee M Lindey Defendant Contract and Indebtedness document preview
  • Wells Fargo Bank NA Plaintiff vs. Shalee M Lindey Defendant Contract and Indebtedness document preview
						
                                

Preview

Filing # 29855855 E-Filed 07/20/2015 03:18:36 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, vs. SHALEE M LINDEY CASE NO. CACE12005633/02 Defendant(s), MOTION TO COMPEL ANSWERS TO PLAINTIFF’S POST JUDGMENT INTERROGATORIES IN AID OF EXECUTION 1. On May 16, 2013 , judgment was entered in favor of WELLS FARGO BANK, N.A., and against SHALEE M LINDEY, in the amount of $76,235.73, plus interest, in the above-captioned case. The Plaintiff, WELLS FARGO BANK, N.A., served interrogatories in aid of execution Pursuant to Fla. R. Civ. P. 1.560 on May 20, 2015. See attached Exhibit "A." 2. To this date, Defendant has failed to respond to Plaintiff’s post judgment interrogatories in aide of execution. 3. It is well-established Florida Law that Fla. R. Civ. P. 1.560 permits a judgment creditor to obtain discovery from the judgment debtor in the manner provided in the Florida Rules of Civil Procedure, in aid of a judgment or execution. 4. In this instant case, Defendant has wholly failed to respond to Plaintiff's discovery requests. It is within the power of this Honorable Court under 1.560 to order Defendant to answer Plaintiff's Interrogatories immediately, and in the manner required under the Florida Rules of Civil Procedure. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 7/20/2015 3:18:36 PM.****WHEREFORE, Plaintiff hereby requests this Honorable Court to grant Plaintiff's Motion to Compe! Answers to Plaintiff's Interrogatories in Aid of Execution and any other order this Court may deem just and proper. NADERPOUR & ASSOCIATES, P.A. Attorneys for Plaintiff 2743 Hollywood Boulevard Hollywood, FL 33020 Primary Service Email Address: eservicel@n: urandassociates.com BY: AMIR NADERPOUR, ESQ., FL BAR: 0070262 JODI M. FOX, ESQ., FL BAR: 0024872 AMBER KETTERER, ESQ., FL BAR: 0098630 SABERIN J. JAMSHED, ESQ., FL BAR: 0088665 “FAUSTO A. ROSALES, ESQ., FL BAR: 0103153 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished by mail on this. Z © _ day of __\ hy , 2015 to: SHALEE M LINDEY at 10896 NW 66TH CT, PARKLAND FL 33076-3802. eye eee [ ] AMIR NADERPOUR, ESQ. { ]JODIM. FOX, ESQ. ] AMBER KETTERER, ESQ. [ LFEAUSTO J. JAMSHED, ESQ. [“TFAUSTO A. ROSALES, ESQ. WELLS FARGO BANK, N.A. v. SHALEE M LINDEY CASE NO. CACE12005633/02 Internal File No.: 13551IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR, BROWARD COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, vs. _ SHALEE M LINDEY Defendant(s), / CASE NO.:CACE12005633/02 CERTIFICATE OF INTERROGATORIES IN AID OF EXECUTION 1 HEREBY CERTIFY that Plaintiff's counsel mailed Interrogatories in Aid of Execution to, SHALEE M LINDEY, at 10896 NW 66TH CT, PARKLAND FL 33076-3802 on this_@e> day of __rete| 015. By: gael [] AMIR NADERPOUR, ESQ., FBN: 0070262 [] JODI M. FOX, ESQ., FBN: 0024872 [] AMBER L, KETTERER, ESQ,, FBN: 0098630 [ |SABERIN J. JAMSHED, ESQ., FBN: 0088665 Weausto ‘A. ROSALES, ESQ, FBN: 103153 Intemal File No.:13551 Exusir AN&A NADERPOUR & ASSOCIATES, P.A. Law Offices 2743 Hollywood Boulevard 7 Telephone (54) 926-4233 Hollywood, Florida 33020 Facsimile (954) 926-4238 E-Service Emalt Amir Naderpour, Esq. eservice |@naderpourandassociates.com Jodi M. Fox, Esq. eservice i lates.com Amber L. Kefterer, Esq. Saberin J. Jomshed. Esq. Fausto A. Rosales, Esq. May 20 2015 SHALEE M LINDEY 10896 NW 66TH CT PARKLAND FL 33076-3802 Re: WELLS FARGO BANK, N.A. vs, SHALEE M LINDEY Case Number: CACE12005633/02 Internal File No.: 13551 Dear Sir or Madam, Enclosed please find Interrogatories in Aid of Execution. Please be advised that to avoid possible further court proceedings, the enclosed Questionnaire needs to be completed and returned to our office no later than 30 days from the date of your receipt of same. Should you have any questions please feel free to contact our office. Thank you for your cooperation to this matter. Very Truly Yours, AMBER L, KETTERER, ESQ. SABERIN J. JAMSHED, ESQ. FAUSTO A. ROSALES, ESQ.IN THE COUNTY COURT OF THE BROWARDJUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, VS. SHALEE M LINDEY Defendant(s), CASE NO: CACE12005633/02 EI ATO! IN Al E iON Full Legal Name: Nicknames or Aliases: Residence Address: Mailing Address (if different): Home Telephone Number: Business Telephone Number: Name of Employer: Address of Employer: Position or Job Description: Rate of Pay: $. per . Average Paycheck: §, per Average Commissions or Bonuses: $ per Commissions or Bonuses are based on. Other Personal Income: $ from (Explain details on the back of this sheet or an additional sheet if necessary.) Social Security Number: Date of birth: Driver's License Number. Marital Status: Spouse’s Name: AIOE SUES HE ESE IGIUI SIG ICIS ROI EI SICA Aa ITO OEE AITO BE RRA RIOR IER PRAT I BE AAA, HoSpouse Related Portion Spouse’s Address (if different): Spouse’s Social Security Number: Date of birth: oo 7 LLL LL Le Spouse’s Employer: Spouse’s Average Paycheck or Income: §, per Other Family Income: $ per. (Explain details on bak of this sheet or an additional sheet if necessary.) Describe all other accounts or investments you may have, including stocks, mutual funds, savings, bonds, or annuities, on the back of this sheet or an additional sheet if necessary. SRR SIG IO a ROIS RRO ORIG COO TOO I ICICI DIOR TOR IGE IIR HO AIR HORI RR AOAC HERE B RH AAR. eee Name and Ages of all your Children (and addresses if not living with you): Child support or Alimony Paid: $. per Names of Others You Live With: Who is Head of Your Household ? You Spouse Other Person Checking Account at: Account #: Savings Account at: Account #; For Real Estate (land) You Own or Are Buying: Address: All Names on Title:, Mortgage Owed to: Balance Owed: Monthly payment: $. (Attach a copy of the deed or mortgage, or list the legal description of the property on the back of this sheet or an additional sheet if necessary. Also provide the same information on any otherproperty you own or are buying.) For All Motor Vehicles You Own or Are Buying: Year/Make/ Model: Color: Vehicle 1D Number: Tag Number: Mileage: Names on Title: Present Value: $. Loan Owed to: Balance on Loan:$ Monthly Payment:$, List all other automobiles, as well as boats, motorcycle or bicycles, or aircraft: Have you given, sold, loaned or transferred any real or personal. property worth more than $100.00 to any person in the last year? If your answer is “yes,” describe the property and sale price, and give the name and address of the person who received the property. Do anyone owe you money? 7 Amount Owed: $. Name and Address of Person Owing Money: Reason money is owed: Please attach copies of the following: A. Your last pay stub. B. Your last three (3) statements for each bank, savings, credit union, or other financial account. C. Your motor vehicle registrations and titles. : D. Any deeds or titles to any real or personal property you own or are buying, or leases to property you are renting. E. Your financial statements, loan applications, or lists of assets and liabilities submitted to any person or entity within the last 3 years. F. Your last 2 income tax returns filed.UNDER PENALTY OF PERJURY, I SWEAR OR AFFIRM THAT THE FORGOING ANSWERS ARE TRUE AND COMPLETE. Judgment Debtor STATE OF FLORIDA COUNTY OF The foregoing instrument was acknowledged before me on day of » by. , who is personally known to me (_) or who has produced identification ( ) and who did/did not take an oath. WITNESS my hand and official seal on day of » 2015. My Commission Expires: Notary Public State of FloridaIN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, vs. SHALEE M LINDEY CASE NO. CACE12005633/02 Defendant(s), Order to Compel Defendant(s) to Complete Form 7.343 ("Fact Information Sheet") The Plaintiff, WELLS FARGO BANK, N.A., has moved for an Order requiring the Defendant(s) to file Answers to Plaintiff's Interrogatories in Aid of Execution. The Court, having considered the Premises, it is hereupon, ORDERED AND ADJUDGED that the Motion is hereby GRANTED. The Defendant is hereby ordered to file Answers to Interrogatories in Aid of Execution, copy attached, and return it to Plaintiff within 20 days from the date of this Order, unless the final judgment is satisfied. ORDERED at BROWARD County, Florida on , 2015. Circuit Court Judge Copies furnished to: NADERPOUR & ASSOCIATES, P.A. 2743 HOLLY WOOD BOULEVARD HOLLYWOOD, FL 33020 SHALEE M LINDEY 10896 NW 66TH CT PARKLAND FL 33076-3802 Internal File No.: 13551IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA WELLS FARGO BANK, N.A. Plaintiff, vs. SHALEE M LINDEY Defendant(s), CASE NO.: CACE12005633/02 INTERROGATORIES IN AID OF EXECUTION Full Legal Name: Nicknames or Aliases: Residence Address: Mailing Address(if different): Home Telephone Number: Business Telephone Number: Name of Employer: Address of Employer: Position or Job Description: Rate of Pay: $ per . Average Paycheck: $. per Average Commissions or Bonuses: $ per Commissions or Bonuses are based on. [ or Other Personal Income: §. from (Explain details on the back of this sheet or an additional sheet if necessary.) Social Security Number: Date of birth: Driver's License Number. Marital Status: Spouse’s Name: Jebed Sone a ieee ia ak footie ieioi iniooi idiuioioisdoi ioioi icinioiak ieik idok tokidoki ioiok ioisi i isiok a i 10 akSpouse Related Portion Spouse’s Address (if different): Spouse’s Social Security Number:. Date of birth: Spouse’s Employer: Spouse’s Average Paycheck or Income: §, per Other Family Income: $ per. (Explain details on bak of this sheet or an additional sheet if necessary.) Describe all other accounts or investments you may have, including stocks, mutual funds, savings, bonds, or annuities, on the back of this sheet or an additional sheet if necessary. AES SSSI EI CI EE IEE SIEGE ISAC IOI A ICCC ACR ICICI I A aR RIO IO CIC AER AC A RR CSI RE a A A Name and Ages of all your Children (and addresses if not living with you): Child support or Alimony Paid: $. ___ per Names of Others You Live With: Who is Head of Your Household ?___ You __ Spouse _____ Other Person Checking Account at: Account #: Savings Account at: Account #: For Real Estate (land) You Own or Are Buying: Address: All Names on Title: Mortgage Owed to: Balance Owed: Monthly payment: $. (Attach a copy of the deed or mortgage, or list the legal description of the property on the back of this sheet or an additional sheet if necessary. Also provide the same information on any other property you own or are buying.)For All Motor Vehicles You Own or Are Buying: Year/Make/ Model: Color: Vehicle ID Number: Tag Number: Mileage: Names on Title: _____ Present Value: $. Loan Owed to: Balance on Loan:$ Monthly Payment:$ List all other automobiles, as well as boats, motorcycle or bicycles, or aircraft: Have you given, sold, loaned or transferred any real or personal property worth more than $100.00 to any person in the last year? If your answer is “yes,” describe the property and sale price, and give the name and address of the person who received the property. Do anyone owe you money? Amount Owed: § Name and Address of Person Owing Money: ___ Reason money is owed: Please attach copies of the following: A. Your last pay stub. B. Your last three (3) statements for each bank, savings, credit union, or other financial account. C. Your motor vehicle registrations and titles. D. Any deeds or titles to any real or personal property you own or are buying, or leases to property you are renting. E. Your financial statements, loan applications, or lists of assets and liabilities submitted to any person or entity within the last 3 years. F, Your last 2 income tax returns filed.UNDER PENALTY OF PERJURY, I SWEAR OR AFFIRM THAT THE FORGOING ANSWERS ARE TRUE AND COMPLETE. Judgment Debtor STATE OF FLORIDA COUNTY OF The foregoing instrument was acknowledged before me on. day of , by, , who is personally known to me (_) or who has produced identification (_) and who did/did not take an oath. WITNESS my hand and official seal on day of » 2015. My Commission Expires: Notary Public State of Florida