Document for REGIONS BANK , sbm Amsouth Bank Plaintiff vs GIBSON, MEL, aka GIBSON, MEL D et al Defendant

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                                Filing # 34968955 E-Filed 11/30/2015 04:48:33 PM

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA

REGIONS BANK SUCCESSOR BY MERGER WITH CASE NO.:
AMSOUTH BANK,

Plaintiff, DIVISION:
VS.

MEL GIBSON A/K/A MEL D. GIBSON; THE UNKNOWN
SPOUSE OF MEL GIBSON A/K/A MEL D. GIBSON; THE
TIMBERS PROPERTY OWNERS ASSOCIATION, INC.;
UNKNOWN TENANT #1 and UNKNOWN TENANT #2,

Defendant(s).
/

PLAINTIFF’S REQUEST FOR ADMISSIONS

Plaintiff, requests, pursuant to Rule 1.370(a) of the Florida Rules of Civil Procedure, that Defendant,
MEL GIBSON A/K/A MEL D. GIBSON, admit the truth of the following matters and the genuineness of the
documents described in the request within the time prescribed by the governing Rule. The term "Defendant"
or "you" in their various forms mean the Defendant to whom these requests are directed.

REQUESTS
Defendant is requested to admit that:

1. Plaintiff has standing to foreclose the mortgage, copy of which is attached Plaintiff's Complaint.

2. Plaintiff is in possession of the original credit agreement and disclosure, a copy of which is attached to
Plaintiff's Complaint.

3. Plaintiff is the holder of the credit agreement and disclosure, a copy of which is attached to Plaintiffs
Complaint.

4. Plaintiff was in possession of the original credit agreement and disclosure, a copy of which is attached
to the Plaintiffs Complaint, on the day the Plaintiff's Complaint was filed.

5. The copy of the credit agreement and disclosure attached to Plaintiff's Complaint is a true and correct
copy of the original credit agreement and disclosure.

6. The copy of the mortgage attached to Plaintiff's Complaint is a true and correct copy of the original
mortgage.

7. All signatures appearing on the credit agreement and disclosure and mortgage, copies of which are attached
to the complaint, are genuine and authentic.

8. The mortgage, a copy of which is attached to Plaintiff's Complaint, constitutes a valid lien on the property
that is the subject of this action.

9. The credit agreement and disclosure and mortgage, copies of which are attached to the Plaintiff's
Complaint, is in default for failing to make the required installment payments as alleged in the Plaintiff's

Complaint.

eFiled Lee County Clerk of Courts Page 110. The credit agreement and disclosure and mortgage, copies of which are attached to the Plaintiffs
Complaint, are in default, as alleged in the Plaintiff's Complaint.

11. Plaintiff sent all notices required by law and in full compliance of the law before the Plaintiff's Complaint
was filed.

12. Before Plaintiff's Complaint was filed, Plaintiff sent all notices, including written notification of the default
and/or acceleration, required by the terms of the credit agreement and disclosure and/or mortgage, copies of
which are attached to Plaintiff's Complaint.

13. All notices that Plaintiff or its agents sent, including written notification of the default and/or acceleration,
fully complied with the terms of the credit agreement and disclosure and/or mortgage, copies of which are
attached to Plaintiff's Complaint.

14. Service of process was properly perfected on the Defendant in compliance with the laws, rules, and
statutes of the State of Florida.

15. Defendant does not have any legal or equitable defense that would prevent entry of a final judgment of
foreclosure in this action.

16. Defendant admits all allegations of the Plaintiffs Complaint.

17. The unpaid principal balance alleged in the Plaintiffs Complaint is accurate.

18. Defendant’s interest in property that is the subject of this action is subordinate to the mortgage, a copy
of which is attached to Plaintiffs Complaint.

19. Plaintiff is entitled to entry of final judgment of foreclosure in this action.

20. Defendant has no reason to delay the entry of final judgment of foreclosure.

21. Plaintiff is legally and equitably entitled to all rent paid to Defendant by any and all tenants residing in
or otherwise occupying the property that is the subject of this action, from the date of default as alleged in

the Plaintiff's Complaint and throughout the pendency of this action.

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing will be served with the summons

and complaint.

THE GEHEREN FIRM, P.C.
4828 Ashford Dunwoody Rd.,
2nd Floor

Atlanta, GA 30338
678.587.9500

E-mail for service: florida@geherenlaw.com

/s/ Jason M. Tarokh
November 30, 2015 JASON M. TAROKH
FLORIDA BAR # 57611

eFiled Lee County Clerk of Courts Page 2