On December 30, 2018 a
Answer
was filed
involving a dispute between
Us Bank National Association,
and
Agrippa, Monica L,
Aqua Finance Inc,
Florida Housing Finance Corporation,
Unknown Spouse Of Monica L Agrippa,
for REAL PROP - HOMESTEAD RES FORECLOSURE2 $50,001 - $249,999
in the District Court of Pinellas County.
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Filing # 83578740 E-Filed 01/18/2019 01:17:31 PM
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PINELLAS COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
U.S. BANK NATIONAL ASSOCIATION,
Plaintiff,
CASE NO. 19-000071-CI
DIVISION:
V.
MONICA L. AGRIPPA, et al.,
Defendants.
/
ANSWER TO VERIFIED COMPLAINT FOR FORECLOSURE OF MORTGAGE
Defendant, Florida Housing Finance Corporation (“Florida Housing”), a public
corporation, answers the Complaint of Plaintiff, U.S. BANK NATIONAL
ASSOCIATION, and states:
COUNT I — MORTGAGE FORECLOSURE
1. The allegations contained in paragraph 1 of the Complaint are admitted for
jurisdictional purposes only.
2. The allegations contained in paragraph 2 of the Complaint are admitted for
jurisdictional purposes only.
3. Florida Housing is without knowledge of the allegations contained in paragraph 3 of
the Complaint.
4. Florida Housing is without knowledge of the allegations contained in paragraph 4 of
the Complaint.
5. Florida Housing is without knowledge of the allegations contained in paragraph 5 of
the Complaint.
***ELECTRONICALLY FILED 01/18/2019 01:17:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Florida Housing is without knowledge of the allegations contained in paragraph 6 of
the Complaint.
Florida Housing is without knowledge of the allegations contained in paragraph 7 of
the Complaint.
Florida Housing is without knowledge of the allegations contained in paragraph 8 of
the Complaint.
Florida Housing is without knowledge of the allegations contained in paragraph 9 of
the Complaint.
10. Florida Housing iswithout knowledge of the allegations contained in paragraph 10 of
the Complaint.
11. Florida Housing iswithout knowledge of the allegations contained in paragraph 11 of
the Complaint.
12. Florida Housing is without knowledge of the allegations contained in paragraph 12 of
the Complaint.
13. Florida Housing is without knowledge of the allegations contained in paragraph 13 of
the Complaint.
14. Florida Housing is without knowledge of the allegations contained in paragraph 14 of
the Complaint.
15. Florida Housing admits the allegations contained in paragraph 15 of the Complaint.
16. Florida Housing is without knowledge of the allegations contained in paragraph 16 of
the Complaint.
WHEREFORE, Florida Housing respectfully requests that if any proceeds remain
after the sale of the property pursuant to Plaintiff’s Complaint, that said proceeds be
awarded to Florida Housing to the extent ofthe balance then owed under the mortgage held
by Florida Housing as described in the Plaintiff’ s Complaint, and for such other and further
relief as the Court deems just and equitable.
MW
Robert J Pierce
Assistant General Counsel
Florida Bar No.: 194048
Attorney for Defendant
Florida Housing Finance Corporation
227 North Bronough Street, Suite 5000
Tallahassee, Florida 32301
(850) 488—4197
Service Email: efiling@floridahousing.org
Email: Robert.pierce@floridahousing.org
CERTIFICATE OF SERVICE
I HEREBY CERTIFY as a registered participant Who uses the Florida Courts e-
Filing Portal, that I have filed and served a true and correct copy of the foregoing Via the
e-Filing Portal in accordance With Rule 2.516, Florida Rules of Judicial Administration on
Robertson, Anschutz & Schneid P. L. mail@rasflaw.com this _1 8_ day of January, 2019.
,4; w
Robert J Pierce
Assistant General Counsel
Preview
Filing # 83578740 E-Filed 01/18/2019 01:17:31 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA GENERAL JURISDICTION DIVISION U.S. BANK NATIONAL ASSOCIATION, Plaintiff, CASE NO. 19-000071-CI DIVISION: V. MONICA L. AGRIPPA, et al., Defendants. / ANSWER TO VERIFIED COMPLAINT FOR FORECLOSURE OF MORTGAGE Defendant, Florida Housing Finance Corporation (“Florida Housing”), a public corporation, answers the Complaint of Plaintiff, U.S. BANK NATIONAL ASSOCIATION, and states: COUNT I — MORTGAGE FORECLOSURE 1. The allegations contained in paragraph 1 of the Complaint are admitted for jurisdictional purposes only. 2. The allegations contained in paragraph 2 of the Complaint are admitted for jurisdictional purposes only. 3. Florida Housing is without knowledge of the allegations contained in paragraph 3 of the Complaint. 4. Florida Housing is without knowledge of the allegations contained in paragraph 4 of the Complaint. 5. Florida Housing is without knowledge of the allegations contained in paragraph 5 of the Complaint. ***ELECTRONICALLY FILED 01/18/2019 01:17:31 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY*** Florida Housing is without knowledge of the allegations contained in paragraph 6 of the Complaint. Florida Housing is without knowledge of the allegations contained in paragraph 7 of the Complaint. Florida Housing is without knowledge of the allegations contained in paragraph 8 of the Complaint. Florida Housing is without knowledge of the allegations contained in paragraph 9 of the Complaint. 10. Florida Housing iswithout knowledge of the allegations contained in paragraph 10 of the Complaint. 11. Florida Housing iswithout knowledge of the allegations contained in paragraph 11 of the Complaint. 12. Florida Housing is without knowledge of the allegations contained in paragraph 12 of the Complaint. 13. Florida Housing is without knowledge of the allegations contained in paragraph 13 of the Complaint. 14. Florida Housing is without knowledge of the allegations contained in paragraph 14 of the Complaint. 15. Florida Housing admits the allegations contained in paragraph 15 of the Complaint. 16. Florida Housing is without knowledge of the allegations contained in paragraph 16 of the Complaint. WHEREFORE, Florida Housing respectfully requests that if any proceeds remain after the sale of the property pursuant to Plaintiff’s Complaint, that said proceeds be awarded to Florida Housing to the extent ofthe balance then owed under the mortgage held by Florida Housing as described in the Plaintiff’ s Complaint, and for such other and further relief as the Court deems just and equitable. MW Robert J Pierce Assistant General Counsel Florida Bar No.: 194048 Attorney for Defendant Florida Housing Finance Corporation 227 North Bronough Street, Suite 5000 Tallahassee, Florida 32301 (850) 488—4197 Service Email: efiling@floridahousing.org Email: Robert.pierce@floridahousing.org CERTIFICATE OF SERVICE I HEREBY CERTIFY as a registered participant Who uses the Florida Courts e- Filing Portal, that I have filed and served a true and correct copy of the foregoing Via the e-Filing Portal in accordance With Rule 2.516, Florida Rules of Judicial Administration on Robertson, Anschutz & Schneid P. L. mail@rasflaw.com this _1 8_ day of January, 2019. ,4; w Robert J Pierce Assistant General Counsel