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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