On May 06, 2008 a
Answer 3233848 Comments: Answer|DEFT KEYSTONE AT MEADOW WOODS HOMEOWNERS ASSOC INC ANSWER
was filed
involving a dispute between
Deutsche Bank National Trust Company,
and
Any And All Unknown Parties Claiming By Through Un,
Argent Mortgage Company Llc,
Edith Patino,
Joaquin Munoz,
Keystone At Meadow Woods Homeowners Association In,
Oakshire At Meadow Woods Homeowners Association In,
Tenant #1,
Tenant #2,
Tenant #3,
Tenant #4,
for CA - Mortgage Foreclosure (filed prior to 6/1/2009)
in the District Court of Orange County.
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IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR ORANGE
COUNTY. FLORIDA
CASE NO. 08-CA-l 0702 DIV 33
DEUTSCHE BANK NATIONAL TRUST COMPANY. AS
TRUSTEE. IN TRUST FOR THE REGISTERED HOLDERS
OF ARGENT SECURITIES INC., ASSET-BACKED
PASS-THROUGH CERTIFICATES. SERIES 2006-M2
Plaintiff.
vs.
JOAQUIN MUNOZ; EDITH PATINO; ANY AND ALL
UNKNOWN PARTIES CLAIMING BY. THROUGH,
UNDER. AND AGAINST THE HEREIN NAMED
INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN
TO BE DEAD OR ALIVE. WHETHER SAID UNKNOWN -x>
PARTIES MAY CLAIM AN INTEREST AS SPOUSES.
HEIRS, DEVISEES. GRANTEES. OR OTHER =S1
CLAIMANTS; ARGENT MORTGAGE COMPANY, LLC; cz-" o^
KEYSTONE AT MEADOW WOOD HOMEOWNERS'
ASSOCIATION. INC.; TENANT#1, TENANT#2. TENANT
#3, and TENANT #4 the names being fictitious to account
for parties in possession
Defendants.
/
ANSWER OF
KEYSTONE AT MEADOW WOODS HOMEOWNERS' ASSOCIATION. INC.
KEYSTONE AT MEADOW WOODS HOMEOWNERS' ASSOCIATION. INC.. hereinafter
"ASSOCIATION" by and through its undersigned attorneys, answers the Plaintiffs Complaint to
Foreclose Mortgage and says:
1. ASSOCIATION is without knowledge as to the allegations contained in paragraphs
1 through 12 and 14 through 21 of Plaintiffs Complaint.
2. As to paragraph 13 of Plaintiffs Complaint. ASSOCIATION admits that ithas a
Notice and Claim of Lien recorded on 01/11/2007. in Official Records Book 9059. Page 4719, of
the Public Records of ORANGE County, Florida, but denies that the Notice and Claim of Lien is
subjectto being extinguished where foreclosure sale proceeds are insufficient to satisfy said claim.
The Association has certain statutory rights against any subsequent title holder pursuant to Section
720.3085, Florida Statutes.
WHEREFORE, the Defendant, KEYSTONE AT MEADOW WOODS HOMEOWNERS-
ASSOCIATION. INC.. requests that, in any judgment entered in this matter, that this court
recognize the Defendant's statutory rights against any subsequent title holder to the property
presently being foreclosed upon pursuant to Section 720.3085, Florida Statutes, and that any
foreclosure sale proceeds in excess of any judgment entered in favor of Plaintiff be handled in
accordance with Section 45.031. Florida Statutes.
I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail delivery to ,
Florida Default Law Group. P.L., P.O. Box 25018. Tampa. FL 33622-5015; and Joaquin Munoz.
Edith Patino, 14038 Boca Key Drive, Orlando, FL 32824, this -^ dav of ^'^^^ 200^.
ERfK FU^YNOT.^ESCf.
FI6ridpKBar#a25170
ewrivnot(5)tavlor-carls.com
PAUL T. HINCKLEY. ESQ.
Florida Bar mOA8146
phincklev(5)tfivlor-carls.com
Taylor & Carls. P.A.
850 Concourse Parkway South. Suite 105
Maitland. Florida 32751
Attorneys for ASSOCIATION
Telephone: (407) 660-1040
Facsimile: (407) 660-9422
Document Filed Date
June 06, 2008
Case Filing Date
May 06, 2008
Category
CA - Mortgage Foreclosure (filed prior to 6/1/2009)
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IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY. FLORIDA CASE NO. 08-CA-l 0702 DIV 33 DEUTSCHE BANK NATIONAL TRUST COMPANY. AS TRUSTEE. IN TRUST FOR THE REGISTERED HOLDERS OF ARGENT SECURITIES INC., ASSET-BACKED PASS-THROUGH CERTIFICATES. SERIES 2006-M2 Plaintiff. vs. JOAQUIN MUNOZ; EDITH PATINO; ANY AND ALL UNKNOWN PARTIES CLAIMING BY. THROUGH, UNDER. AND AGAINST THE HEREIN NAMED INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE DEAD OR ALIVE. WHETHER SAID UNKNOWN -x> PARTIES MAY CLAIM AN INTEREST AS SPOUSES. HEIRS, DEVISEES. GRANTEES. OR OTHER =S1 CLAIMANTS; ARGENT MORTGAGE COMPANY, LLC; cz-" o^ KEYSTONE AT MEADOW WOOD HOMEOWNERS' ASSOCIATION. INC.; TENANT#1, TENANT#2. TENANT #3, and TENANT #4 the names being fictitious to account for parties in possession Defendants. / ANSWER OF KEYSTONE AT MEADOW WOODS HOMEOWNERS' ASSOCIATION. INC. KEYSTONE AT MEADOW WOODS HOMEOWNERS' ASSOCIATION. INC.. hereinafter "ASSOCIATION" by and through its undersigned attorneys, answers the Plaintiffs Complaint to Foreclose Mortgage and says: 1. ASSOCIATION is without knowledge as to the allegations contained in paragraphs 1 through 12 and 14 through 21 of Plaintiffs Complaint. 2. As to paragraph 13 of Plaintiffs Complaint. ASSOCIATION admits that ithas a Notice and Claim of Lien recorded on 01/11/2007. in Official Records Book 9059. Page 4719, of the Public Records of ORANGE County, Florida, but denies that the Notice and Claim of Lien is subjectto being extinguished where foreclosure sale proceeds are insufficient to satisfy said claim. The Association has certain statutory rights against any subsequent title holder pursuant to Section 720.3085, Florida Statutes. WHEREFORE, the Defendant, KEYSTONE AT MEADOW WOODS HOMEOWNERS- ASSOCIATION. INC.. requests that, in any judgment entered in this matter, that this court recognize the Defendant's statutory rights against any subsequent title holder to the property presently being foreclosed upon pursuant to Section 720.3085, Florida Statutes, and that any foreclosure sale proceeds in excess of any judgment entered in favor of Plaintiff be handled in accordance with Section 45.031. Florida Statutes. I HEREBY CERTIFY that a copy of the foregoing has been furnished by mail delivery to , Florida Default Law Group. P.L., P.O. Box 25018. Tampa. FL 33622-5015; and Joaquin Munoz. Edith Patino, 14038 Boca Key Drive, Orlando, FL 32824, this -^ dav of ^'^^^ 200^. ERfK FU^YNOT.^ESCf. FI6ridpKBar#a25170 ewrivnot(5)tavlor-carls.com PAUL T. HINCKLEY. ESQ. Florida Bar mOA8146 phincklev(5)tfivlor-carls.com Taylor & Carls. P.A. 850 Concourse Parkway South. Suite 105 Maitland. Florida 32751 Attorneys for ASSOCIATION Telephone: (407) 660-1040 Facsimile: (407) 660-9422