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IN THE CIRCUIT COURT OF THE
12TH JUDICIAL CIRCUIT, IN AND
FOR SARASOTA COUNTY,
FLORIDA
CIVIL DIVISION
AURORA LOAN SERVICES, LLC
Plaintiff,
VS.
CASE NO.: 2007 CA 8006 NC
BEDRI BEGANI AND MILENA BEGANI,
HIS WIFE; BANK OF AMERICA, N.A.; et al,
ne “"
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Defendants. OVE a 3
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ANSWER TO COMPLAINT
COMES NOW, Defendant, BANK OF AMERICA, N.A., as custodian or trustee, by and through
follows:
its undersigned counsel, hereby files this its Answer to Plaintiff's Complaint, and in support states as
l.
Defendant, BANK OF AMERICA, N.A.., is without knowledge, paragraphs | through 10 and
paragraphs 12 through 13, same and demands strict proof thereof.
2. Defendant admits paragraph || in that BANK OF AMERICA, N.A., has an interest by virtue of
its mortgage, but denies that its interest ts infertor.
3.
Defendant, BANK OF AMERICA, N.A., ts without knowledge as to all allegations in
Plaintiff's Complaint and demands strict proof thereof.
AFFIRMATIVE DEFENSES
4. Defendant, BANK OF AMERICA, N.A., holds a mortgage, which its interest ts superior to all
remaining defendants and therefore is entitled to an award of all surpluses to satisfy its claim.
07-14226
(itThimenyyWHEREFORE, Defendant, BANK OF AMERICA, N.A., as a junior lienholder, respectfully
requests that this Honorable court reserve jurisdiction to determine the priority of the Defendant and
award Defendant excess proceeds, and for such other, further relief that this Court deems just and proper.
I HEREBY vmalthis a true copy of the foregoing was delivered to the parties on the
attached mailing list by mail this day of _-_ August __, 2007.
Law Offices of Marshall C. Watson, P.A.
1800 N.W. 49" Street, Suite 120
07-14226ANSWER TO COMPLAINT / CASE NO.: 2007 CA 8006 NC
SERVICE LIST
LAW OFFICES OF MARSHALL C. WATSON, P.A.
C/o KATHLEEN ANGIONE, ESQ.
ATTORNEY FOR DEFENDANT, BANK OF AMERICA, N.A.
1800 N.W. 49'" STREET
SUITE 120
FORT LAUDERDALE, FLORIDA 33309
SPEAR & HOFFMAN, P.A.
C/o L. JOSEPH HOFFMAN, ESQ.
ATTORNEY FOR PLAINTIFF
9700 SOUTH DIXIE HIGHWAY
SUITE 610
MIAMI, FLORIDA 33156
BEDRI BEGANI AND MILENA BEGANI, HIS WIFE
3485 PARKRIDGE CIRCLE
SARASOTA, FLORIDA 34243
07-14226
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IN THE CIRCUIT COURT OF THE 12TH JUDICIAL CIRCUIT, IN AND FOR SARASOTA COUNTY, FLORIDA CIVIL DIVISION AURORA LOAN SERVICES, LLC Plaintiff, VS. CASE NO.: 2007 CA 8006 NC BEDRI BEGANI AND MILENA BEGANI, HIS WIFE; BANK OF AMERICA, N.A.; et al, ne “" Ga LO = win ve ~ mas 1 yes eS G? ” i O vt C2 - aN em on > OQ" “0 2 co Ti ae a ery mits of) ae erin Ae ws iy, Defendants. OVE a 3 CA G mn SG cyt — Ba — yY ANSWER TO COMPLAINT COMES NOW, Defendant, BANK OF AMERICA, N.A., as custodian or trustee, by and through follows: its undersigned counsel, hereby files this its Answer to Plaintiff's Complaint, and in support states as l. Defendant, BANK OF AMERICA, N.A.., is without knowledge, paragraphs | through 10 and paragraphs 12 through 13, same and demands strict proof thereof. 2. Defendant admits paragraph || in that BANK OF AMERICA, N.A., has an interest by virtue of its mortgage, but denies that its interest ts infertor. 3. Defendant, BANK OF AMERICA, N.A., ts without knowledge as to all allegations in Plaintiff's Complaint and demands strict proof thereof. AFFIRMATIVE DEFENSES 4. Defendant, BANK OF AMERICA, N.A., holds a mortgage, which its interest ts superior to all remaining defendants and therefore is entitled to an award of all surpluses to satisfy its claim. 07-14226 (itThimenyyWHEREFORE, Defendant, BANK OF AMERICA, N.A., as a junior lienholder, respectfully requests that this Honorable court reserve jurisdiction to determine the priority of the Defendant and award Defendant excess proceeds, and for such other, further relief that this Court deems just and proper. I HEREBY vmalthis a true copy of the foregoing was delivered to the parties on the attached mailing list by mail this day of _-_ August __, 2007. Law Offices of Marshall C. Watson, P.A. 1800 N.W. 49" Street, Suite 120 07-14226ANSWER TO COMPLAINT / CASE NO.: 2007 CA 8006 NC SERVICE LIST LAW OFFICES OF MARSHALL C. WATSON, P.A. C/o KATHLEEN ANGIONE, ESQ. ATTORNEY FOR DEFENDANT, BANK OF AMERICA, N.A. 1800 N.W. 49'" STREET SUITE 120 FORT LAUDERDALE, FLORIDA 33309 SPEAR & HOFFMAN, P.A. C/o L. JOSEPH HOFFMAN, ESQ. ATTORNEY FOR PLAINTIFF 9700 SOUTH DIXIE HIGHWAY SUITE 610 MIAMI, FLORIDA 33156 BEDRI BEGANI AND MILENA BEGANI, HIS WIFE 3485 PARKRIDGE CIRCLE SARASOTA, FLORIDA 34243 07-14226