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Filing # 129663810 E-Filed 06/28/2021 05:31:21 PM
IN THE CIRCUIT COURT OF THE SEVENTEENTHJUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
DANIANS SOUTH CONDOMINIUM
ASSOCIATION, INC.
Case No. CACE-21-7282
Plaintiff.
DIVISION: Civil (12)
V
RAFFAELE PANTALEO, et al.,
Defendants.
I
DEFENDANT FRIDOUS ASLAM's ANSWERS AND AFFIRMATIVE DEFENSES
COMES NOW, Defendant, FIRDOUS ASLAM, by and through the undersigned counsel
and hereby files her Answers and Affirmative Defenses, and as grounds thereof states the
following:
I ANSWER
1. Defendant admits the allegations in paragraph 1 of the Complaint for jurisdictional
purposes only.
2. Defendant admits the allegations as set forth in paragraph 6 ofthe Complaint.
3. Defendant is without knowledge as to the allegations as set forth in paragraphs 2,3,4,5,
7, and 9 through 14 of the Complaint and, therefore, deny the allegations and demand
strict proof thereof.
4. Any allegations not expressly and specifically admitted shall be generally denied.
II. AFFIRMATIVE DEFENSES
5. Defendant, FIRDOUS ASLAM "(ASLAM"), is a "subordinatelienholder" as defined by
Florida Statute § 45.032 to the property that is subject to Plaintiff's Complaint by virtue of
the Final Judgment After Defaultexecuted on January 13,2021 and recorded in the official
Page 1 of 2
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/28/2021 05:31:20 PM.****
DANIANS SOUTH CONDOMINIUM Case No. CACE-21-7282
ASSOCIATION,INC. v. RAFFAELE PANTALEO, et al. Answer & Affirmative Defenses
records ofBroward County on January 13, 2021 as instrumentnumber 116986323. A true
and correct copy ofthe Order ofFinal Judgment After Defaultis attached hereto as Exhibit
"A." Therefore, ASLAM is entitled to any surplus funds after the Plaintiff's final judgment
is satisfied as evidenced by the certificate of disbursements. ASLAM asserts that the Court
may determine her right to surplus funds in the amount of the final judgment, accrued
interest, attorney's fees and costs in accordance with § 45.032(b), Florida Statutes.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing document is being
served, pursuant to Rule 2.516(b), Fla. R. Jud. Admin., via Florida Courts e-Filing Portal to the
names and email addresses provided by all parties, counsel of record and Ra/aele Pantaleo on
June 28, 2021 by United State Mail at 501 Est Dania Beach Blvd., Apt. 5-5F, Dania Beach, FL
33004.
The Law Office of Vinicius Adam
511 SE 5th Ave.,
Suite 104
FortLauderdale, FL 33301
Phone: (954) 451-0792
Fax: (267) 430-8862
By: /s/ Vinicius Adam
Vinicius Adam
Fla. Bar No. 116536
Primary Service Email:
Attorney for Defendant
Page 2 of 2
"
EXH13111 "A
Filing # 119551180 E-Filed 01/13/2021 12:32:46 PM
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE19002769 DIVISION 05 JUDGE Martin Bidwill
Firdous Aslam
Plaintiff(s) / Petitioner(s)
V.
Raffaele Pantaleo
Defendant(s) / Respondent(s)
'
FINAL JUDGMENT AFTER DEFAULT
THIS CAUSE came to be heard on the Plaintiffs Motion for Final Judgment, and the Court
having reviewed the pleadings herein, and otherwise being fully advised in the premises, it is
ORDERED, ADJUDGED, and DECREED that the said Plaintiff, FIRDOUS ASLAM
(hereinafter "Plaintiff"), does have and recover of and from said Defendant, RAFFAELE
PANTALEO the principal amount of $22,910.00, attorneys' fees in the amount of $2,640.00
and costs in the amount of $443.50, making a total sum of $25,993.50 that shall bear interest
at the statutory rate after the entry of this Final Judgment, for which let execution issue.
Jurisdiction of this cause is reserved for the entry of an Order with regard to further post-
judgment attorney's fees and costs pursuant to Florida Statute §57.115.
It is further ordered and adjudged that the judgment debtor(s) shall complete under oath
Form 1.977 (Fact Information Sheet), including all required attachments, and serve it on the
judgment creditor's attorney, or the judgment creditor if the judgment creditor is not
represented by an attorney, within forty-five (45) days from the date of this final judgment,
unless the final judgment is satisfied, or post-judgment discovery is stayed. Form 1.977
accompanies this Final Judgment.
Jurisdiction of this case is retained to enter further orders that are proper to compel the
CaseNo: CACE19002769
Page 2 of 2
judgment debtor(s) to complete form 1.977 including all required attachments, and any other
discovery in aid of execution, garnishment or other collection procedures. As such, actions
taken by the Plaintiff to collect on this Judgment which may require Court intervention will not
be charged a "re-opening" fee pursuant to Florida Statutes §28.241. This is notwithstanding
the fact that this case may have been previously reported as disposed of and being
resubmitted to the Court for further proceedings.
The last known address of the Defendants/ Judgment Debtors RAFFAELE PANTALEO is
501 East Dania Beach Blvd., Unit 5-5F, Dania Beach, Florida 33004.
The address for the Plaintiffs/Judgment Creditors, FIRDOUS ALSM 501 East Dania Beach
Blvd., Unit 5-1 F, Dania Beach, Florida 33004.
DONE and ORDERED in Chambers, at Broward County, Florida on 01-13-2021.
V v l.:.amx
I Lz..OMX.C
CACE19002769 01-13-2021 11:22 AM
Hon. Martin Bidwill
CIRCUIT JUDGE
Electronically Signed by Martin Bidwill
Copies Furnished To:
Alan M. Blose,Esq. E-mail :
,
Alan Michael Blose, E-mail :
Alan Michael Blose, E-mail :
Christine Smalarz, E-mail :
David Chaiet, E-mail :
David Chaiet, E-mail :
Erik D. Diener, E-mail :
RAFFAELE PANTALEO Address ,
: 501 East Dania Beach Blvd., Unit 5-5F, Dania Beach,
Florida 33004
Vinicius Adam, E-mail :
Vinicius Adam, E-mail :
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Filing # 129663810 E-Filed 06/28/2021 05:31:21 PM IN THE CIRCUIT COURT OF THE SEVENTEENTHJUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA DANIANS SOUTH CONDOMINIUM ASSOCIATION, INC. Case No. CACE-21-7282 Plaintiff. DIVISION: Civil (12) V RAFFAELE PANTALEO, et al., Defendants. I DEFENDANT FRIDOUS ASLAM's ANSWERS AND AFFIRMATIVE DEFENSES COMES NOW, Defendant, FIRDOUS ASLAM, by and through the undersigned counsel and hereby files her Answers and Affirmative Defenses, and as grounds thereof states the following: I ANSWER 1. Defendant admits the allegations in paragraph 1 of the Complaint for jurisdictional purposes only. 2. Defendant admits the allegations as set forth in paragraph 6 ofthe Complaint. 3. Defendant is without knowledge as to the allegations as set forth in paragraphs 2,3,4,5, 7, and 9 through 14 of the Complaint and, therefore, deny the allegations and demand strict proof thereof. 4. Any allegations not expressly and specifically admitted shall be generally denied. II. AFFIRMATIVE DEFENSES 5. Defendant, FIRDOUS ASLAM "(ASLAM"), is a "subordinatelienholder" as defined by Florida Statute § 45.032 to the property that is subject to Plaintiff's Complaint by virtue of the Final Judgment After Defaultexecuted on January 13,2021 and recorded in the official Page 1 of 2 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 06/28/2021 05:31:20 PM.**** DANIANS SOUTH CONDOMINIUM Case No. CACE-21-7282 ASSOCIATION,INC. v. RAFFAELE PANTALEO, et al. Answer & Affirmative Defenses records ofBroward County on January 13, 2021 as instrumentnumber 116986323. A true and correct copy ofthe Order ofFinal Judgment After Defaultis attached hereto as Exhibit "A." Therefore, ASLAM is entitled to any surplus funds after the Plaintiff's final judgment is satisfied as evidenced by the certificate of disbursements. ASLAM asserts that the Court may determine her right to surplus funds in the amount of the final judgment, accrued interest, attorney's fees and costs in accordance with § 45.032(b), Florida Statutes. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing document is being served, pursuant to Rule 2.516(b), Fla. R. Jud. Admin., via Florida Courts e-Filing Portal to the names and email addresses provided by all parties, counsel of record and Ra/aele Pantaleo on June 28, 2021 by United State Mail at 501 Est Dania Beach Blvd., Apt. 5-5F, Dania Beach, FL 33004. The Law Office of Vinicius Adam 511 SE 5th Ave., Suite 104 FortLauderdale, FL 33301 Phone: (954) 451-0792 Fax: (267) 430-8862 By: /s/ Vinicius Adam Vinicius Adam Fla. Bar No. 116536 Primary Service Email: Attorney for Defendant Page 2 of 2 " EXH13111 "A Filing # 119551180 E-Filed 01/13/2021 12:32:46 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE19002769 DIVISION 05 JUDGE Martin Bidwill Firdous Aslam Plaintiff(s) / Petitioner(s) V. Raffaele Pantaleo Defendant(s) / Respondent(s) ' FINAL JUDGMENT AFTER DEFAULT THIS CAUSE came to be heard on the Plaintiffs Motion for Final Judgment, and the Court having reviewed the pleadings herein, and otherwise being fully advised in the premises, it is ORDERED, ADJUDGED, and DECREED that the said Plaintiff, FIRDOUS ASLAM (hereinafter "Plaintiff"), does have and recover of and from said Defendant, RAFFAELE PANTALEO the principal amount of $22,910.00, attorneys' fees in the amount of $2,640.00 and costs in the amount of $443.50, making a total sum of $25,993.50 that shall bear interest at the statutory rate after the entry of this Final Judgment, for which let execution issue. Jurisdiction of this cause is reserved for the entry of an Order with regard to further post- judgment attorney's fees and costs pursuant to Florida Statute §57.115. It is further ordered and adjudged that the judgment debtor(s) shall complete under oath Form 1.977 (Fact Information Sheet), including all required attachments, and serve it on the judgment creditor's attorney, or the judgment creditor if the judgment creditor is not represented by an attorney, within forty-five (45) days from the date of this final judgment, unless the final judgment is satisfied, or post-judgment discovery is stayed. Form 1.977 accompanies this Final Judgment. Jurisdiction of this case is retained to enter further orders that are proper to compel the CaseNo: CACE19002769 Page 2 of 2 judgment debtor(s) to complete form 1.977 including all required attachments, and any other discovery in aid of execution, garnishment or other collection procedures. As such, actions taken by the Plaintiff to collect on this Judgment which may require Court intervention will not be charged a "re-opening" fee pursuant to Florida Statutes §28.241. This is notwithstanding the fact that this case may have been previously reported as disposed of and being resubmitted to the Court for further proceedings. The last known address of the Defendants/ Judgment Debtors RAFFAELE PANTALEO is 501 East Dania Beach Blvd., Unit 5-5F, Dania Beach, Florida 33004. The address for the Plaintiffs/Judgment Creditors, FIRDOUS ALSM 501 East Dania Beach Blvd., Unit 5-1 F, Dania Beach, Florida 33004. DONE and ORDERED in Chambers, at Broward County, Florida on 01-13-2021. V v l.:.amx I Lz..OMX.C CACE19002769 01-13-2021 11:22 AM Hon. Martin Bidwill CIRCUIT JUDGE Electronically Signed by Martin Bidwill Copies Furnished To: Alan M. Blose,Esq. E-mail : , Alan Michael Blose, E-mail : Alan Michael Blose, E-mail : Christine Smalarz, E-mail : David Chaiet, E-mail : David Chaiet, E-mail : Erik D. Diener, E-mail : RAFFAELE PANTALEO Address , : 501 East Dania Beach Blvd., Unit 5-5F, Dania Beach, Florida 33004 Vinicius Adam, E-mail : Vinicius Adam, E-mail :