Preview
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/2/2013 1:12:39 PM.****
Electronically Filed 08/02/2013 01:12:39 PM ET
IN THE CIRCUIT COURT OF THE
17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 12-34985 CACE 11
HELM BANK USA, A FLORIDA CORPORATION,
f/k/a HELM BANK, A FLORIDA CORPORATION,
Plaintiff,
vs.
FREDDY DE CORDOVA, ET AL.,
Defendants.
PEPE EEE ey
NOTICE OF FILING DOCUMENTS
COMES NOW, the Plaintiff, HELM BANK USA, A FLORIDA CORPORATION, by and through
their undersigned counsel and submit this Notice of Filing Documents pursuant to Rule 1.370 Florida Rules
of Civil Procedure and submitted as attachments the Plaintiff's Response to Defendant’s First set of
Interrogatories.
CERTIFICATE OF SERVICE
+o
1 HEREBY CERTIFY that a copy of this Notice of Filing was electronically submitted on this a®
day of August, 2013 to: John H. Ruiz, Esquire at fmartinez @lawolficeslaley.com
CASTRO & RAMIREZ, LLC
1805 PONCE DE LEON BLVD., SUITE 500
CORAL GABLES, FLORIDA 33134
Tel:(305)372-2800
Email: mramirez@ca
By:
MANUEL A. RAMIREZ, ESQUIREFirst Set of Interrogatories
State the name and address of all parties answering or assisting in providing
answers to these interrogatories.
ANSWER: | Calixto Guerra Reinoso
999 Brickell Ave, Miami, FL 33131
If you did not admit to Plaintiff's Request for Admissions numbers 1 through
30, please set forth with specificity the factual basis for denying any of the
requests for admissions or if you are claiming insufficient knowledge.
ANSWER: Object to the form of the question.
Please state if the credit extended to the Defendant(s) in this transaction and
secured by a promissory note and mortgage allegedly signed by the
Defendant(s) was secured by the Defendant(s) principal dwelling.
ANSWER: NO
Please state the nature of the annual percentage rate being sued upon by
Plaintiff in this lawsuit. By nature of the annual percentage rate (APR)
Defendant(s) seeks to know if the interest rate being charged on the alleged
note and mortgage held by Plaintiff is a fixed APR or a variable APR.
ANSWER: The note speaks for itself.
Please provide a detail description where in Plaintiffs documents Defendant
can find the manner in which any changes in the annual percentage rate will be
made including; any negative amortization and interest rate carryover; the
timing of any such changes; any index or margin to which such changes in the
rate are related and or tied to as it pertains to the note and mortgage sued upon
and forming part of this litigation.
ANSWER; The note
La Ley con John H. Ruiz, P.A.
5040 NW 7* Street, Suite 500, Miami. Florida 33126 (305) 649-0020Was the initial APR offered to Defendant based on an index; if so please
describe to Defendant where a statement of such rate and a period of time such
initial rate will be in effect as well as a statement that such rate does not
include cost other than interest.
ANSWER: The note
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant a statement describing to Defendant the risk involved in obtaining
credit by securing the loan and or mortgage with the property covered by the
Mortgage sued upon in this litigation? If so, please advise when that
information was provided to Defendant and in what manner, as well as
explaining who provided that information and where that information was
provided to Defendant and whether or not there was disclosure to Defendant
of the highest and lowest payments that were possible based on variable
interest rates pursuant to the note and mortgage.
ANSWER: Object to the form of the question
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant with a statement of the amount financed, using that term, which
shall be the amount of credit of which the Defendant has actual use as it
pertains to the note and mortgage sued upon in this litigation either before the
credit was extended to Defendant or was that information placed in the mail
not later than 3 business days after the creditor received the consumer’s
written application. If so, please advise when that information was provided to
Defendant and in what manner, as well as explaining who provided that
information and where that information was provided to Defendant.
ANSWER: Yes.
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant with a statement of the consumer’s right to obtain, upon a written
request, a written itemization of the amount financed as it pertains to the note
and mortgage sued upon in this litigation either before the credit was extended
to Defendant or was that information placed in the mail not later than 3
business days after the creditor received the consumer’s written application. If
so, please advise when that information was provided to Defendant and in
what manner, as well as explaining who provided that information and where
that information was provided to Defendant.
La Ley con John H. Ruiz, P.A.
5040 NW 7* Street, Suite 500, Mian, Florida 13126 (308) 649-002010.
i.
12.
43.
ANSWER: Yes.
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant with a statement that a security interest has been taken in the
property which is purchased as part of the note and mortgage sued upon in this
litigation either before the credit was extended to Defendant or was that
information placed in the mail not later than 3 business days after the creditor
received the consumer’s written application. If so, please advise when that
information was provided to Defendant and in what manner, as well as
explaining who provided that information and where that information was
provided to Defendant.
ANSWER: _ Object to the form of the question
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant with a statement that the interest on the portion of the credit
extension that is greater than the fair market value of the dwelling is not tax
deductible for Federal income tax purposes; and the consumer should consult
a tax adviser for further information regarding the deductibility of interest and
charges as it pertains to the note and mortgage sued upon in this litigation
either before the credit was extended to Defendant or was that information
placed in the mail not later than 3 business days after the creditor received the
consumer’s written application. If so, please advise when that information was
provided to Defendant and in what manner, as well as explaining who
provided that information and where that information was provided to
Defendant.
ANSWER: N/A
Did Plaintiff and or its agents or assigns or predecessors in interest provide
Defendant with a booklet titled Consumer Handbook on Adjustable Rate
Mortgages published by the Board and the Federal Home Loan Bank Board, or
a suitable substitute before the credit was extended to Defendant. If so, please
advise when that information was provided to Defendant and in what manner,
as well as explaining who provided that information and where that
information was provided to Defendant.
ANSWER: Yes
Did Plaintiff and or its agents or assigns or predecessors in interest provide
La Ley con John H. Ruiz, P.A.
5040 NW 7* Street, Suite 500, Miami, Florida 33126 (305) 649-002014,
16.
Defendant with two copies of the notice of the right to rescind to each
consumer entitled to rescind, as it pertains to the note and mortgage sued upon
in this litigation. If so, please advise when that information was provided to
Defendant and in what manner, as well as explaining who provided that
information and where that information was provided to Defendant.
ANSWER: N/A
Did Plaintiff and or its agents or assigns or predecessors in interest pay a Yield
Spread Premium to a third party as it pertains to the note and mortgage sued
upon in this litigation. If so, please provide defendant with the name of the
person or entity that received the Yield Spread Premium and the amount of the
Yield Spread Premium.
ANSWER: Yes , documentation included in production documents.
If a Yield Spread Premium was paid to a third party as it pertains to the note
and mortgage sued upon in this litigation was that Yield Spread Premium
disclosed the Defendant in the HUD-1 form.
ANSWER: Yes
If a Yield Spread Premium was paid to a third party as it pertains to the note
and mortgage sued upon in this litigation was any amount of the Yield Spread
Premium paid by the Defendant directly or indirectly. More specifically was
any part of the Yield Spread Premium financed within the Note presented to
Defendant.
ANSWER: Object to the form of the question
Please describe which document provided to Defendant in connection with the
note and mortgage sued upon and forming part of this litigation discloses to
Defendant the dollar amount(s) of the largest and smallest payments that
Defendant might be responsible to make in the instance that the credit
extended to Defendant is in the form of a variable interest rate that adjust in
any fashion after the execution of the Note and Mortgage.
ANSWER: Object to the form of the question
La Ley con John H. Ruiz, P.A.
$040 NW 7” Strect, Suite 500, Miami, Flonda 33126 (305) 649-002018,
19,
20.
21.
Please state whether you claim to possess legal or beneficial interest, or both
interests, in the note or mortgage or both the note and mortgage, and if so,
explain why you so claim identifying any document(s) and clauses therein
which gives you the interest(s) you claim and specifying whether you claim
tights as an owner or holder of the note or both, and specifying any other
rights claimed. If you do not claim any such interest(s) or rights please
explain why you do not claim such interest(s).
ANSWER: Note and Mortgage are made to Plaintiff.
Please state whether you claim to possess the authority or power to file and
pursue foreclosure of this note or mortgage or both, and if so, explain why you
so claim identifying any document(s) and clauses therein which gives you the
authority or power you claim. Provide the exact date when you claim to have
obtained possession of the note and/or assignment of the mortgage. Specify, as
to the note, whether it was by blank endorsement or special endorsement and
if so, the name of the records custodian that has knowledge and is qualified to
meet all the business records exception to the hearsay rule. If you do not claim
any such authority or power please explain why you do not claim such
authority or power.
ANSWER; _ Plaintiff own the note and Mortgage.
Please state from what person or entity (“assignor”) you took assignment of
the note and/or mortgage specifying the contact name, full legal name,
address, and phone number of the assignor together with the date you took
assignment, and state the same information for any person or entity to which
the Loan was ever assigned.
ANSWER: = N/A
Please state the date, amount and nature of and fully describe the consideration
or value given in exchange for each and every assignment of the note and/or
mortgage and identify from and to what person or entity such consideration or
value was given providing the contact name, full legal name, address, and
phone number of each such person or entity.
ANSWER: N/A
La Ley con John H. Ruiz, P.A.
5040 NW 7* Suet, Suite 500, Miami, Florida 33126 (305) 649-002022.
23,
24,
25.
26.
Please state all parties that took assignment of the note and/or mortgage
between the making of same and your taking assignment of same and provide
the contact name, full legal name, address, and phone number of each such
party.
ANSWER: N/A
Please state whether between the time of making the Loan and the time of
your taking assignment of the note and/or mortgage the original lender
maintained ownership of the Loan and whether or not there was any default of
the loan prior to or when taking an assignment of the loan.
ANSWER: N/A
Please state whether and on what date the plaintiff owned the note and/or
mortgage, took assignment of the note and/or mortgage, made an assignment
of the note and/or mortgage, or had any interest in the note and/or mortgage
and specify the nature of the interest had on that date.
ANSWER: N/A
Please identify each and every document which contains an obligation or
option to repurchase the subject mortgage loan and explain fully the terms,
conditions, costs to be incurred or paid by each party upon repurchase and
whether and by whom, and from whom, the mortgage loan were ever
repurchased.
ANSWER: N/A
Please state if the note and/or mortgage was ever subject to or included in a
“mortgage loan purchase agreement” or similar agreement and if so, please
specify the name to the agreement, the date of the agreement and any
amendments, and the parties to the agreements.
ANSWER: NIA
La Ley con John H. Ruiz, P.A.
5040 NW 7° Suet, Suite 500, Miami, Florida 33126 (105) 649-002027.
28.
29.
30.
Please identify a representative of Plaintiff with knowledge of the facts
necessary to respond to each of the interrogatories contained herein or if more
than one, identify each such representative providing the name, address and
telephone number for each with a brief summary of each representative’s
knowledge in this matter.
ANSWER: Calixto Guerra Reinoso
Provide the name of the corporate representative(s) that has knowledge of the
details of all payments and/or credits from the inception of the subject to the
date of the claimed failure of payment by the Defendant(s).
ANSWER: _ Object to the form of the question.
Describe, in detail, if the subject loan falls into any potential settlement or
other mandated Department of Justice settlement and/or Independent
Foreclosure Review.
ANSWER; No.
Does the Plaintiff have any loss share agreement and/or any other insurance or
other indemnification from any source whatsoever other than from the
Defendant? If so, state the name, policy or other indemnification source and
whether or not any claim has been made. Also, please provide full details of
all the insurance policies that cover Plaintiff for any claim relative to any
potential loss or other claim pertaining to the note and/or mortgage that is the
basis of this lawsuit.
ANSWER: N/A
La Ley con John H. Ruiz, P.A.
5040 NW 7” Strvet, Suite 500, Miami, Florida 33126 (305) 649-0020VERIFICATION
I swear and affirm that the foregoing angwe interrogatories are true and
accurate.
o<
Calixto Guerra Reinosg
Special Assets Manarige
STATE OF FLORIDA
COUNTY OF Miaaii: t ade
The foregoing instrument was acknowledged before me thi l day of
2013, by, VECO Talos, who:
( is personally known to me, or
identification.
() has produced
Public, State of Florida
Commission Expires: {-11-1S
SUANITA DELEON
MY COMMISSION #EE116393
EXPIRES: SEP 11, 2015
Bonded tough 1st State Insurance
La Ley con John H. Ruiz, P.A.
$040 NW 7° Sucet, Suite $00, Miami, Florida 33126 (305) 649-0020
Preview
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/2/2013 1:12:39 PM.**** Electronically Filed 08/02/2013 01:12:39 PM ET IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. 12-34985 CACE 11 HELM BANK USA, A FLORIDA CORPORATION, f/k/a HELM BANK, A FLORIDA CORPORATION, Plaintiff, vs. FREDDY DE CORDOVA, ET AL., Defendants. PEPE EEE ey NOTICE OF FILING DOCUMENTS COMES NOW, the Plaintiff, HELM BANK USA, A FLORIDA CORPORATION, by and through their undersigned counsel and submit this Notice of Filing Documents pursuant to Rule 1.370 Florida Rules of Civil Procedure and submitted as attachments the Plaintiff's Response to Defendant’s First set of Interrogatories. CERTIFICATE OF SERVICE +o 1 HEREBY CERTIFY that a copy of this Notice of Filing was electronically submitted on this a® day of August, 2013 to: John H. Ruiz, Esquire at fmartinez @lawolficeslaley.com CASTRO & RAMIREZ, LLC 1805 PONCE DE LEON BLVD., SUITE 500 CORAL GABLES, FLORIDA 33134 Tel:(305)372-2800 Email: mramirez@ca By: MANUEL A. RAMIREZ, ESQUIREFirst Set of Interrogatories State the name and address of all parties answering or assisting in providing answers to these interrogatories. ANSWER: | Calixto Guerra Reinoso 999 Brickell Ave, Miami, FL 33131 If you did not admit to Plaintiff's Request for Admissions numbers 1 through 30, please set forth with specificity the factual basis for denying any of the requests for admissions or if you are claiming insufficient knowledge. ANSWER: Object to the form of the question. Please state if the credit extended to the Defendant(s) in this transaction and secured by a promissory note and mortgage allegedly signed by the Defendant(s) was secured by the Defendant(s) principal dwelling. ANSWER: NO Please state the nature of the annual percentage rate being sued upon by Plaintiff in this lawsuit. By nature of the annual percentage rate (APR) Defendant(s) seeks to know if the interest rate being charged on the alleged note and mortgage held by Plaintiff is a fixed APR or a variable APR. ANSWER: The note speaks for itself. Please provide a detail description where in Plaintiffs documents Defendant can find the manner in which any changes in the annual percentage rate will be made including; any negative amortization and interest rate carryover; the timing of any such changes; any index or margin to which such changes in the rate are related and or tied to as it pertains to the note and mortgage sued upon and forming part of this litigation. ANSWER; The note La Ley con John H. Ruiz, P.A. 5040 NW 7* Street, Suite 500, Miami. Florida 33126 (305) 649-0020Was the initial APR offered to Defendant based on an index; if so please describe to Defendant where a statement of such rate and a period of time such initial rate will be in effect as well as a statement that such rate does not include cost other than interest. ANSWER: The note Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant a statement describing to Defendant the risk involved in obtaining credit by securing the loan and or mortgage with the property covered by the Mortgage sued upon in this litigation? If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant and whether or not there was disclosure to Defendant of the highest and lowest payments that were possible based on variable interest rates pursuant to the note and mortgage. ANSWER: Object to the form of the question Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant with a statement of the amount financed, using that term, which shall be the amount of credit of which the Defendant has actual use as it pertains to the note and mortgage sued upon in this litigation either before the credit was extended to Defendant or was that information placed in the mail not later than 3 business days after the creditor received the consumer’s written application. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. ANSWER: Yes. Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant with a statement of the consumer’s right to obtain, upon a written request, a written itemization of the amount financed as it pertains to the note and mortgage sued upon in this litigation either before the credit was extended to Defendant or was that information placed in the mail not later than 3 business days after the creditor received the consumer’s written application. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. La Ley con John H. Ruiz, P.A. 5040 NW 7* Street, Suite 500, Mian, Florida 13126 (308) 649-002010. i. 12. 43. ANSWER: Yes. Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant with a statement that a security interest has been taken in the property which is purchased as part of the note and mortgage sued upon in this litigation either before the credit was extended to Defendant or was that information placed in the mail not later than 3 business days after the creditor received the consumer’s written application. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. ANSWER: _ Object to the form of the question Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant with a statement that the interest on the portion of the credit extension that is greater than the fair market value of the dwelling is not tax deductible for Federal income tax purposes; and the consumer should consult a tax adviser for further information regarding the deductibility of interest and charges as it pertains to the note and mortgage sued upon in this litigation either before the credit was extended to Defendant or was that information placed in the mail not later than 3 business days after the creditor received the consumer’s written application. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. ANSWER: N/A Did Plaintiff and or its agents or assigns or predecessors in interest provide Defendant with a booklet titled Consumer Handbook on Adjustable Rate Mortgages published by the Board and the Federal Home Loan Bank Board, or a suitable substitute before the credit was extended to Defendant. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. ANSWER: Yes Did Plaintiff and or its agents or assigns or predecessors in interest provide La Ley con John H. Ruiz, P.A. 5040 NW 7* Street, Suite 500, Miami, Florida 33126 (305) 649-002014, 16. Defendant with two copies of the notice of the right to rescind to each consumer entitled to rescind, as it pertains to the note and mortgage sued upon in this litigation. If so, please advise when that information was provided to Defendant and in what manner, as well as explaining who provided that information and where that information was provided to Defendant. ANSWER: N/A Did Plaintiff and or its agents or assigns or predecessors in interest pay a Yield Spread Premium to a third party as it pertains to the note and mortgage sued upon in this litigation. If so, please provide defendant with the name of the person or entity that received the Yield Spread Premium and the amount of the Yield Spread Premium. ANSWER: Yes , documentation included in production documents. If a Yield Spread Premium was paid to a third party as it pertains to the note and mortgage sued upon in this litigation was that Yield Spread Premium disclosed the Defendant in the HUD-1 form. ANSWER: Yes If a Yield Spread Premium was paid to a third party as it pertains to the note and mortgage sued upon in this litigation was any amount of the Yield Spread Premium paid by the Defendant directly or indirectly. More specifically was any part of the Yield Spread Premium financed within the Note presented to Defendant. ANSWER: Object to the form of the question Please describe which document provided to Defendant in connection with the note and mortgage sued upon and forming part of this litigation discloses to Defendant the dollar amount(s) of the largest and smallest payments that Defendant might be responsible to make in the instance that the credit extended to Defendant is in the form of a variable interest rate that adjust in any fashion after the execution of the Note and Mortgage. ANSWER: Object to the form of the question La Ley con John H. Ruiz, P.A. $040 NW 7” Strect, Suite 500, Miami, Flonda 33126 (305) 649-002018, 19, 20. 21. Please state whether you claim to possess legal or beneficial interest, or both interests, in the note or mortgage or both the note and mortgage, and if so, explain why you so claim identifying any document(s) and clauses therein which gives you the interest(s) you claim and specifying whether you claim tights as an owner or holder of the note or both, and specifying any other rights claimed. If you do not claim any such interest(s) or rights please explain why you do not claim such interest(s). ANSWER: Note and Mortgage are made to Plaintiff. Please state whether you claim to possess the authority or power to file and pursue foreclosure of this note or mortgage or both, and if so, explain why you so claim identifying any document(s) and clauses therein which gives you the authority or power you claim. Provide the exact date when you claim to have obtained possession of the note and/or assignment of the mortgage. Specify, as to the note, whether it was by blank endorsement or special endorsement and if so, the name of the records custodian that has knowledge and is qualified to meet all the business records exception to the hearsay rule. If you do not claim any such authority or power please explain why you do not claim such authority or power. ANSWER; _ Plaintiff own the note and Mortgage. Please state from what person or entity (“assignor”) you took assignment of the note and/or mortgage specifying the contact name, full legal name, address, and phone number of the assignor together with the date you took assignment, and state the same information for any person or entity to which the Loan was ever assigned. ANSWER: = N/A Please state the date, amount and nature of and fully describe the consideration or value given in exchange for each and every assignment of the note and/or mortgage and identify from and to what person or entity such consideration or value was given providing the contact name, full legal name, address, and phone number of each such person or entity. ANSWER: N/A La Ley con John H. Ruiz, P.A. 5040 NW 7* Suet, Suite 500, Miami, Florida 33126 (305) 649-002022. 23, 24, 25. 26. Please state all parties that took assignment of the note and/or mortgage between the making of same and your taking assignment of same and provide the contact name, full legal name, address, and phone number of each such party. ANSWER: N/A Please state whether between the time of making the Loan and the time of your taking assignment of the note and/or mortgage the original lender maintained ownership of the Loan and whether or not there was any default of the loan prior to or when taking an assignment of the loan. ANSWER: N/A Please state whether and on what date the plaintiff owned the note and/or mortgage, took assignment of the note and/or mortgage, made an assignment of the note and/or mortgage, or had any interest in the note and/or mortgage and specify the nature of the interest had on that date. ANSWER: N/A Please identify each and every document which contains an obligation or option to repurchase the subject mortgage loan and explain fully the terms, conditions, costs to be incurred or paid by each party upon repurchase and whether and by whom, and from whom, the mortgage loan were ever repurchased. ANSWER: N/A Please state if the note and/or mortgage was ever subject to or included in a “mortgage loan purchase agreement” or similar agreement and if so, please specify the name to the agreement, the date of the agreement and any amendments, and the parties to the agreements. ANSWER: NIA La Ley con John H. Ruiz, P.A. 5040 NW 7° Suet, Suite 500, Miami, Florida 33126 (105) 649-002027. 28. 29. 30. Please identify a representative of Plaintiff with knowledge of the facts necessary to respond to each of the interrogatories contained herein or if more than one, identify each such representative providing the name, address and telephone number for each with a brief summary of each representative’s knowledge in this matter. ANSWER: Calixto Guerra Reinoso Provide the name of the corporate representative(s) that has knowledge of the details of all payments and/or credits from the inception of the subject to the date of the claimed failure of payment by the Defendant(s). ANSWER: _ Object to the form of the question. Describe, in detail, if the subject loan falls into any potential settlement or other mandated Department of Justice settlement and/or Independent Foreclosure Review. ANSWER; No. Does the Plaintiff have any loss share agreement and/or any other insurance or other indemnification from any source whatsoever other than from the Defendant? If so, state the name, policy or other indemnification source and whether or not any claim has been made. Also, please provide full details of all the insurance policies that cover Plaintiff for any claim relative to any potential loss or other claim pertaining to the note and/or mortgage that is the basis of this lawsuit. ANSWER: N/A La Ley con John H. Ruiz, P.A. 5040 NW 7” Strvet, Suite 500, Miami, Florida 33126 (305) 649-0020VERIFICATION I swear and affirm that the foregoing angwe interrogatories are true and accurate. o< Calixto Guerra Reinosg Special Assets Manarige STATE OF FLORIDA COUNTY OF Miaaii: t ade The foregoing instrument was acknowledged before me thi l day of 2013, by, VECO Talos, who: ( is personally known to me, or identification. () has produced Public, State of Florida Commission Expires: {-11-1S SUANITA DELEON MY COMMISSION #EE116393 EXPIRES: SEP 11, 2015 Bonded tough 1st State Insurance La Ley con John H. Ruiz, P.A. $040 NW 7° Sucet, Suite $00, Miami, Florida 33126 (305) 649-0020