On January 31, 2014 a
Motion,Ex Parte
was filed
involving a dispute between
Us Bank National Association,
and
Georgia Wolfe,
Mortgage Electronic Registration Systmes Inc,
Unknown Tenants Owners,
Us Bank National Association,
for HR FORECLOSURE = > $250K
in the District Court of Palm Beach County.
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*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK.***
Filing # 12961362 Electronically Filed 04/25/2014 04:37:51 PM
IN THE CIRCUIT COURT OF THE FIFTEETH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION.
U.S. BANK NATIONAL ASSOCIATION, ETC.
Plaintiff, Case Number: 502014CA001256XXXXMB
v.
GEORGIA WOLFE, ete.,
Defendants.
MOTION TO FILE A SECOND AMENDED ANSWER
AND MOTION TO FILE COUNTER CLAIM
The Defendant, GEORGIA WOLFE, by her undersigned attorney, hereby moves this
court for an order allowing her to file a second amended answer and a motion to file counter
claim and as grounds for said motion would show the court that defendant omitted two
affirmative defenses and a claim for attorneys” fees and needs to allege these for this claim.
The grounds for the counter claim became available as the defendant researched the issues.
No prejudice will result to the plaintiff by granting this motion. The defendant would show
also that the case has not yet been set for trial, amendment should be freely granted, and the
defendant does not believe the case is at issue at the present time.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document was
furnished by email this 25th day of April, 2014 to:
Edward B. Pritchard, Esq., Kass Shuler, 1505 N. Florida Ave., P.O, Box 800, Tampa, FL
33602-0800 at: EPritcha@kasslaw.com and ForeclosureService@kasslaw.com, and to John
M. Jorgensen, Esq., Scott, Harris, Bryan, Barra & Jorgensen, P.A., 4400 PGA Blvd., Suite
800, Palm Beach Gardens, FL 33410 at: Pleadings@Scott-Harris.com and
JMJorgensen@cott-Harris.com,
78
By ARK 1
fy Allan L, Hoffman, Esq.
Ayo Allan L. Hoffman, P.A,
Attorney for Defendant, Wolfe
1610 Southern Blvd.
West Palm Beach, FL 33406
FBN: 131739
Phone: 561-478-7066
Fax: 561-697-8317
mail: alhl@juno.com
FEN:
S752
Document Filed Date
April 25, 2014
Case Filing Date
January 31, 2014
Category
HR FORECLOSURE = > $250K
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*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK.*** Filing # 12961362 Electronically Filed 04/25/2014 04:37:51 PM IN THE CIRCUIT COURT OF THE FIFTEETH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA. CIVIL DIVISION. U.S. BANK NATIONAL ASSOCIATION, ETC. Plaintiff, Case Number: 502014CA001256XXXXMB v. GEORGIA WOLFE, ete., Defendants. MOTION TO FILE A SECOND AMENDED ANSWER AND MOTION TO FILE COUNTER CLAIM The Defendant, GEORGIA WOLFE, by her undersigned attorney, hereby moves this court for an order allowing her to file a second amended answer and a motion to file counter claim and as grounds for said motion would show the court that defendant omitted two affirmative defenses and a claim for attorneys” fees and needs to allege these for this claim. The grounds for the counter claim became available as the defendant researched the issues. No prejudice will result to the plaintiff by granting this motion. The defendant would show also that the case has not yet been set for trial, amendment should be freely granted, and the defendant does not believe the case is at issue at the present time. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document was furnished by email this 25th day of April, 2014 to: Edward B. Pritchard, Esq., Kass Shuler, 1505 N. Florida Ave., P.O, Box 800, Tampa, FL 33602-0800 at: EPritcha@kasslaw.com and ForeclosureService@kasslaw.com, and to John M. Jorgensen, Esq., Scott, Harris, Bryan, Barra & Jorgensen, P.A., 4400 PGA Blvd., Suite 800, Palm Beach Gardens, FL 33410 at: Pleadings@Scott-Harris.com and JMJorgensen@cott-Harris.com, 78 By ARK 1 fy Allan L, Hoffman, Esq. Ayo Allan L. Hoffman, P.A, Attorney for Defendant, Wolfe 1610 Southern Blvd. West Palm Beach, FL 33406 FBN: 131739 Phone: 561-478-7066 Fax: 561-697-8317 mail: alhl@juno.com FEN: S752