On May 20, 2008 a
Answer 3411363 Comments: Answer|DEFT THE REGISTRY AT MICHIGAN PARK CONDO ASSOC INC ANSWER TO COMPLAINT
was filed
involving a dispute between
The Bank Of New York,
and
Any And All Unknown Parties Claiming By Through U,
Donnie Margjokaj,
Tenant #1,
Tenant #2,
Tenant #3,
Tenant #4,
The Registry At Michigan Park Condominium Associat,
The Unknown Spouse Of Donnie Margjokaj,
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 .A.ND FOR ORANGE
COUNTY- FLORIDA
CASE No. 08-CA-12092
THE BANK OF NEW YORK, as successor ^
in interest to JP Morgan Chase Bank, N..A., ^ . '^ •< <..
as Trustee for the Holders of SAMI 11, 2006
AR4, Mortgage Pass-Through Certificates,
Series 2006-AR4,
Plainfiff
vs.
DONNI MARGJOKAJ. ET. AL.
Defendants.
ANSWER TO COMPLAINT
COMES NOW, Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM
ASSOCIATION, INC., by and through their undersigned counsel and files this their Answer to
Plaintiffs Complaint, and alleges as follows:
1. The Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM
ASSOCIATION, fNC, admits the allegations contained in paragraph 13, that it may have a claim
or claims for unpaid assessments, if any, but is without knowledge that said claims are inferior to and
are subject to PlaintifiPs Mortgage lien, therefore denies said allegations ofthe Plaintiff
2. The Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM
ASSOCIATION, INC., is without knowledge as to the other allegations, and will therefore deny the
same and demands strict proof thereof
WHEREFORE, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM
ASSOCIATION, INC., requests that the Court determine the validity and priority of all
encumbrances, claims, mortgages, liens ofjudgment on the subject property; including Defendant's
claim for unpaid assessments if and when the sale is ordered by the Court, said Defendant requests
that provisions be made for the Clerk to receive in its registry the pioceeds of sale and disbursement
be made in accordance with the Cou;-.'s findings as to priority lien holders or claimants.
I HEREBY CERTIFY that a true and correct copy ofthe foregoing was sent by U.S. Mail to
Brian R. Alvarez, Esquire, P.O. Box 25018, Tampa, Florida 33622-5018 this 9 day of July,
2008.
'E^^LETCHER, ESQUIRE
lette S. Fletcher, P.A.
•lorida Bar No.: 658251
156 S. Charles Richard Beall Blvd., Suite 2
Debaiv, Florida327I3
(386) 668-4446
Attorney for Defendant The Registry at Michigan
Park Condominium .Association. Inc.
Document Filed Date
July 11, 2008
Case Filing Date
May 20, 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 .A.ND FOR ORANGE COUNTY- FLORIDA CASE No. 08-CA-12092 THE BANK OF NEW YORK, as successor ^ in interest to JP Morgan Chase Bank, N..A., ^ . '^ •< <.. as Trustee for the Holders of SAMI 11, 2006 AR4, Mortgage Pass-Through Certificates, Series 2006-AR4, Plainfiff vs. DONNI MARGJOKAJ. ET. AL. Defendants. ANSWER TO COMPLAINT COMES NOW, Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM ASSOCIATION, INC., by and through their undersigned counsel and files this their Answer to Plaintiffs Complaint, and alleges as follows: 1. The Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM ASSOCIATION, fNC, admits the allegations contained in paragraph 13, that it may have a claim or claims for unpaid assessments, if any, but is without knowledge that said claims are inferior to and are subject to PlaintifiPs Mortgage lien, therefore denies said allegations ofthe Plaintiff 2. The Defendant, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM ASSOCIATION, INC., is without knowledge as to the other allegations, and will therefore deny the same and demands strict proof thereof WHEREFORE, THE REGISTRY AT MICHIGAN PARK CONDOMINIUM ASSOCIATION, INC., requests that the Court determine the validity and priority of all encumbrances, claims, mortgages, liens ofjudgment on the subject property; including Defendant's claim for unpaid assessments if and when the sale is ordered by the Court, said Defendant requests that provisions be made for the Clerk to receive in its registry the pioceeds of sale and disbursement be made in accordance with the Cou;-.'s findings as to priority lien holders or claimants. I HEREBY CERTIFY that a true and correct copy ofthe foregoing was sent by U.S. Mail to Brian R. Alvarez, Esquire, P.O. Box 25018, Tampa, Florida 33622-5018 this 9 day of July, 2008. 'E^^LETCHER, ESQUIRE lette S. Fletcher, P.A. •lorida Bar No.: 658251 156 S. Charles Richard Beall Blvd., Suite 2 Debaiv, Florida327I3 (386) 668-4446 Attorney for Defendant The Registry at Michigan Park Condominium .Association. Inc.