On June 27, 2007 a
Exhibit,Appendix
was filed
involving a dispute between
Household Finance Corporation Iii,
and
Smith, Susan,
in the District Court of Sarasota County.
Preview
85299764.001/D458MJP/01/19/2009/459/BN#3 125G/CID#
IN THE COUNTY COURT IN THE 12TH JUDICIAL
CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA
HOUSEHOLD FINANCE CORPORATION
o's
Plaintiff, 3 Xn
vs. CASE NUMBER: 07-CC-4310 SC 3 BS, Zo.
CE, GS HA
SUSAN SMITH Bee Oe
OE OR
Ae oe
Defendant(s). VA Pye. 3 2B,
ee FLORIDA BAR ID# 264547 ACE A
“Ge OD
MOTION FOR JUDGMENT ON THE PLEADINGS “OG:
TO: SUSAN SMITH
3200 RUSTIC RD.
NOKOMIS, FL 34275
COMES NOW, the Plaintiff, HOUSEHOLD FINANCE CORPORATION, by and through its
undersigned counsel, and files this its Motion for Judgment on the Pleadings and would show unto this
Honorable Court the following:
1. Pursuant to the Complaint filed by the Plaintiff in the above captioned of action, it 1s the position
of the Plaintiff, that the Defendant is indebted to the Plaintiff for the benefit of sums advanced for and on behalf
of same and although due demand had been made, the Defendant defaulted with respect the repayment of same
which precipitated the suit in the above captioned cause.
2. After service of the Complaint in the above captioned cause of action upon the Defendant, the
Defendant filed a reply to same indicating that the Defendant is in fact indebted to the Plaintiff but can not
afford to repay the debt in issue. A copy of that Answer is attached hereto and incorporated hereby reference.
3, As noted pursuant to the Complaint filed in the above captioned cause of action, the Defendant is
indebted to the Plaintiff for and in the sum of $9045.65, not including interest, court costs and attorneys fees if
(etic
any.4. In support of the foregoing Motion, the Plaintiff has filed prior to the date hereof, the requisite
Affidavits in Support of the Entry of a Final Order in favor of the Plaintiff.
WHEREFORE all premises considered, it is respectfully prayed this Honorable Court enter a Judgment
on the Pleadings in favor of the Plaintiff against the Defendant together with interest, court costs and attorney
fees and for any and all further relief that this Honorable Court deem just and proper.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the original of the foregoing Motion for Judgment on the Pleadings was mailed to
the above named addressee this day of _ , 20
Respectfully subAtiat Q, 2003
Stanley B. Erskine, Esquire
The Law Offices
ERSKINE & FLEISHER
Attorneys for Plaintiff
Suite 300, 55 Weston Road
Fort Lauderdale, Florida 33326
Telephone No. (954) 384-1490
Telecopier No. (954) 384-4088
Toll Free No. (800) 397-9345
Email: Customerservice@Eflaw.net ,
By:
Stanley B. Erskine, Esgt (re
Attachment: Copy of Defendant’s Pro Se Answer}
g HS-316104001 10712 12:27:58 20 JUN 2008
lune 1Ay Qoe H5 -21172/ 0059, RECEVED tok
> 4
Ta bya oe
WAGNER & HUNT PA
cam writing in fesPonSe to | Your letter
of WN a4 12, 1008, You otftered me rs
Sum. of ff le Yoo ** do Settle Gn ada out
as have toith Household Finance Corp.
HS-31172100590237 16:36:00 21 "ef 2008
Dear rian } ae rence |
Tye teed byt Gan nest get this ane
Sum G\\ TT Can of Ser aot WiS +i me
Q Detter pay ment whenever FL gett
Additional Cy“ Dloum ent)
| &¢F
" Sweerety — ——-— a Lee. =
Su San “T. Anite, Lou Se hold . Fonance Cop
3 Ade Rustic Ra
Acer ® Bip iouoollayt
Moko mig Fl 34275 *
Document Filed Date
February 09, 2009
Case Filing Date
June 27, 2007
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
85299764.001/D458MJP/01/19/2009/459/BN#3 125G/CID# IN THE COUNTY COURT IN THE 12TH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA HOUSEHOLD FINANCE CORPORATION o's Plaintiff, 3 Xn vs. CASE NUMBER: 07-CC-4310 SC 3 BS, Zo. CE, GS HA SUSAN SMITH Bee Oe OE OR Ae oe Defendant(s). VA Pye. 3 2B, ee FLORIDA BAR ID# 264547 ACE A “Ge OD MOTION FOR JUDGMENT ON THE PLEADINGS “OG: TO: SUSAN SMITH 3200 RUSTIC RD. NOKOMIS, FL 34275 COMES NOW, the Plaintiff, HOUSEHOLD FINANCE CORPORATION, by and through its undersigned counsel, and files this its Motion for Judgment on the Pleadings and would show unto this Honorable Court the following: 1. Pursuant to the Complaint filed by the Plaintiff in the above captioned of action, it 1s the position of the Plaintiff, that the Defendant is indebted to the Plaintiff for the benefit of sums advanced for and on behalf of same and although due demand had been made, the Defendant defaulted with respect the repayment of same which precipitated the suit in the above captioned cause. 2. After service of the Complaint in the above captioned cause of action upon the Defendant, the Defendant filed a reply to same indicating that the Defendant is in fact indebted to the Plaintiff but can not afford to repay the debt in issue. A copy of that Answer is attached hereto and incorporated hereby reference. 3, As noted pursuant to the Complaint filed in the above captioned cause of action, the Defendant is indebted to the Plaintiff for and in the sum of $9045.65, not including interest, court costs and attorneys fees if (etic any.4. In support of the foregoing Motion, the Plaintiff has filed prior to the date hereof, the requisite Affidavits in Support of the Entry of a Final Order in favor of the Plaintiff. WHEREFORE all premises considered, it is respectfully prayed this Honorable Court enter a Judgment on the Pleadings in favor of the Plaintiff against the Defendant together with interest, court costs and attorney fees and for any and all further relief that this Honorable Court deem just and proper. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the original of the foregoing Motion for Judgment on the Pleadings was mailed to the above named addressee this day of _ , 20 Respectfully subAtiat Q, 2003 Stanley B. Erskine, Esquire The Law Offices ERSKINE & FLEISHER Attorneys for Plaintiff Suite 300, 55 Weston Road Fort Lauderdale, Florida 33326 Telephone No. (954) 384-1490 Telecopier No. (954) 384-4088 Toll Free No. (800) 397-9345 Email: Customerservice@Eflaw.net , By: Stanley B. Erskine, Esgt (re Attachment: Copy of Defendant’s Pro Se Answer} g HS-316104001 10712 12:27:58 20 JUN 2008 lune 1Ay Qoe H5 -21172/ 0059, RECEVED tok > 4 Ta bya oe WAGNER & HUNT PA cam writing in fesPonSe to | Your letter of WN a4 12, 1008, You otftered me rs Sum. of ff le Yoo ** do Settle Gn ada out as have toith Household Finance Corp. HS-31172100590237 16:36:00 21 "ef 2008 Dear rian } ae rence | Tye teed byt Gan nest get this ane Sum G\\ TT Can of Ser aot WiS +i me Q Detter pay ment whenever FL gett Additional Cy“ Dloum ent) | &¢F " Sweerety — ——-— a Lee. = Su San “T. Anite, Lou Se hold . Fonance Cop 3 Ade Rustic Ra Acer ® Bip iouoollayt Moko mig Fl 34275 *