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Filing # 66330436 E-Filed 01/09/2018 10:43:13 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY
FLORIDA OPPORTUNITY REAL ESTATE
INVESTMENT, LLC,
Plaintiff(s),
v. Case No.: 17-000587-CA.
WILFREDO MILAN; LISSETTE REIGOSA;
ALL UNKNOWN PARTIES CLAIMING
INTERESTS BY, THROUGH, UNDER OR
AGAINST A NAMED DEFENDANT TO THIS
ACTION, OR HAVING OR CLAIMING TO
HAVE ANY RIGHT, TITLE OR INTEREST IN
THE PROPERTY HEREIN DESCRIBED;
UNKNOWN TENANT #1; UNKNOWN
TENANT #2,
Defendant(s).
/
NOTICE OF SERVICE OF DEFENDANTS RESPONSE TO PLAINTIFFS
REQUEST FOR ADMISSIONS
COMES NOW the Defendant, WILFREDO MILAN AND LISSETTE REIGOSA,
(hereinafter “Defendants”), by and through his undersigned counsel and pursuant to Rule 1.370,
Fla. R. Civ. Pro., and hereby submit their Response to the Plaintiff's First Request for Admissions.
/s/
Jacqulyn Mack-Majka, Esquire
Florida Bar No.: 0134902
MACK LAW FIRM CHARTERED
Primary: eservicel@macklawfirm.org
Secondary: eservice2@macklawfirm.org
2022 Placida Road
Englewood, Florida 34224-5204
Mack Law Firm Chartered £ www. MackLawFimn org
2022 Placida Road * Englewood Florida 24224-5204 < (041) 66
This pleading serves as designation of e
Kawfira.org,(941) 475-7966
(941) 475-0729 fax
Attorney for Defendant Milan
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by e-mail to all counsel of record via the Florida Courts E-Filing Portal on January 09, 2018.
isi
, Esquire
Tripp Scott, P.A.
H. Michael Solloa, Jr.
110 SE 6th Street
15th floor
Ft. Lauderdale, FL 33301
954-765-2918
mxs@trippscott.com
Mack Law Firm Chartered 4 www.MackLawFim
2022 Placida Road {+ Englewood Flosids 75 7
This pleading serves as designation of eservice adr
nacklavfirn org,IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY
FLORIDA OPPORTUNITY REAL ESTATE
INVESTMENT, LLC,
Plaintiff(s),
v. Case No.: 17-000587-CA
WILFREDO MILAN; LISSETTE REIGOSA;
ALL UNKNOWN PARTIES CLAIMING
INTERESTS BY, THROUGH, UNDER OR
AGAINST A NAMED DEFENDANT TO THIS
ACTION, OR HAVING OR CLAIMING TO
HAVE ANY RIGHT, TITLE OR INTEREST IN
THE PROPERTY HEREIN DESCRIBED;
UNKNOWN TENANT #1; UNKNOWN
TENANT #2,
Defendant(s).
/
DEFENDANTS’ RESPONSE TO FIRST REQUEST FOR ADMISSIONS
COMES NOW the Defendants, WILFREDO MILAN AND LISETTE REIGOSA,
(hereinafter “Defendants”), by and through undersigned counsel and pursuant to Rule 1.370, Fla.
R. Civ. Pro., and hereby submits their Response to Plaintiff's Request for Admissions.
Mack Law Firm Chartered £ www. MackLawFimn org
2022 Placida Road * Englewood Florida 24224-5204 < (041) 66
This pleading serves as designation of e
Kawfira.org,1. Defendant Milan objects to this request and denies this request because the original
wet- ink Note has not been filed with the Clerk of Court. As a result he cannot
confirm that the copy attached to Plaintiffs complaint is a true and correct copy of
the original wet-ink Note that he signed. Defendant has made a reasonable inquiry
and can state that he did execute a Note in April, 2005, securing indebtedness of
$130,500.00.
2. Defendants object to this Request because the term “genuine” is not defined. In
addition, Defendant Milan objects to this request and denies this request because
the original wet- ink Note has not been filed with the Clerk of Court. As a result he
cannot confirm that the copy attached to Plaintiff's complaint is a true and correct
copy of the original wet-ink Note that he signed. Defendant has made a reasonable
inquiry and can state that he did execute a Note in April, 2005, securing
indebtedness of $130,500.00.
3. Defendants object to this Request because the phrase “the Note” is not defined. In
addition, Defendant Milan objects to this request and denies this request because
the original wet- ink Note has not been filed with the Clerk of Court (assuming that
is the Note referred to in the Request). As a result he cannot confirm that the copy
attached to Plaintiffs complaint is a true and correct copy of the original wet-ink
Note that he signed. Defendant has made a reasonable inquiry and can state that he
did execute a Note in April, 2005, securing indebtedness of $130,500.00.
4. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion, the term “the installment” is not defined.
5. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion, the term “the installment” and the phrase
“event of default” are not defined.
6. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion and the phrase “breached the terms of the
note” is not defined.
7. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion and he does not know what a “Breach Letter”
refers to.
Mack Law Finm Chaztered w
2022 Placida Road + Englewood Florida 2422.
This pleading serves as desiguation of e-serv fresses, eser chianutie Jes raacklavefiren 07g,
pursue to Fla, R. Juck. Admin, 2.5168. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion. Defendant Milan has examined the
Mortgage and Note and cannot find the phrase “Breach Letter” in either document.
9. Defendant Milan has made a reasonable inquiry and the information he knows or
can readily obtain is insufficient to enable him to admit or deny this request because
it appears to require a legal conclusion and the term “default” is not defined.
10. Defendant has made a reasonable inquiry and the information he knows or can
readily obtain is insufficient to enable him to admit or deny this request because he
is not privy to the Plaintiff's decisions.
11. Defendant has made a reasonable inquiry and the information he knows or can
readily obtain is insufficient to enable him to admit or deny this request because he
thought the Note was discharged in his bankruptcy.
12. Defendant has made a reasonable inquiry and the information he knows or can
readily obtain is insufficient to enable him to admit or deny this request because he
thought the Note was discharged in his bankruptcy.
13. Defendants object to this Request because the phrase “the Note” is not defined.
Defendants have made a reasonable inquiry and can state that they did execute a
Mortgage in April, 2005, securing indebtedness of $130,500.00.
14. Defendants object to this request and deny this request because the original wet-
ink Mortgage has not been filed with the Clerk of Court. As a result they cannot
confirm that the copy attached to Plaintiffs complaint is a true and correct copy of
the original wet-ink Mortgage that they signed. Defendants have made a reasonable
inquiry and can state that they did execute a Mortgage in April, 2005.
15. Defendants object to this Request because the phrase “the Mortgage” is not defined.
Defendants have made a reasonable inquiry and can state that they did execute a
Mortgage in April, 2005, securing indebtedness of $130,500.00.
Jacqulyn Mack-Majka, Esquire
Florida bar No.: 0134902
MACK LAW FIRM CHARTERED
Primary: eservicel @macklawfirm.org
Mack Law Firm Chartered 4 www.MackLawFim
2022 Placida Road {+ Englewood Flosids 7
This pleading serves as designation of eservice adr
nacklavfirn org,Secondary: eservice2@macklawfirm.org
2022 Placida Road
Englewood, Florida 34224-5204
(941) 475-7966
(941) 475-0729 fax
Attorney for Milan and Reigosa
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
by e-mail to all counsel of record via the Florida Courts E-Filing Portal on January 9, 2018.
/s/ Jacqulyn Mack-Majka
Jacqulyn Mack-Majka, Esquire
Tripp Scott, P.A.
H. Michael Solloa, Jr.
110 SE 6th Street
15th floor
Ft. Lauderdale, FL 33301
954-765-2918
mxs@trippscott.com
Mack Law Firm Chartered 4 www.MackLawFim
2022 Placida Road {+ Englewood Flosids 75 7
This pleading serves as designation of eservice adr
nacklavfirn org,
Preview
Filing # 66330436 E-Filed 01/09/2018 10:43:13 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY FLORIDA OPPORTUNITY REAL ESTATE INVESTMENT, LLC, Plaintiff(s), v. Case No.: 17-000587-CA. WILFREDO MILAN; LISSETTE REIGOSA; ALL UNKNOWN PARTIES CLAIMING INTERESTS BY, THROUGH, UNDER OR AGAINST A NAMED DEFENDANT TO THIS ACTION, OR HAVING OR CLAIMING TO HAVE ANY RIGHT, TITLE OR INTEREST IN THE PROPERTY HEREIN DESCRIBED; UNKNOWN TENANT #1; UNKNOWN TENANT #2, Defendant(s). / NOTICE OF SERVICE OF DEFENDANTS RESPONSE TO PLAINTIFFS REQUEST FOR ADMISSIONS COMES NOW the Defendant, WILFREDO MILAN AND LISSETTE REIGOSA, (hereinafter “Defendants”), by and through his undersigned counsel and pursuant to Rule 1.370, Fla. R. Civ. Pro., and hereby submit their Response to the Plaintiff's First Request for Admissions. /s/ Jacqulyn Mack-Majka, Esquire Florida Bar No.: 0134902 MACK LAW FIRM CHARTERED Primary: eservicel@macklawfirm.org Secondary: eservice2@macklawfirm.org 2022 Placida Road Englewood, Florida 34224-5204 Mack Law Firm Chartered £ www. MackLawFimn org 2022 Placida Road * Englewood Florida 24224-5204 < (041) 66 This pleading serves as designation of e Kawfira.org,(941) 475-7966 (941) 475-0729 fax Attorney for Defendant Milan CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-mail to all counsel of record via the Florida Courts E-Filing Portal on January 09, 2018. isi , Esquire Tripp Scott, P.A. H. Michael Solloa, Jr. 110 SE 6th Street 15th floor Ft. Lauderdale, FL 33301 954-765-2918 mxs@trippscott.com Mack Law Firm Chartered 4 www.MackLawFim 2022 Placida Road {+ Englewood Flosids 75 7 This pleading serves as designation of eservice adr nacklavfirn org,IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY FLORIDA OPPORTUNITY REAL ESTATE INVESTMENT, LLC, Plaintiff(s), v. Case No.: 17-000587-CA WILFREDO MILAN; LISSETTE REIGOSA; ALL UNKNOWN PARTIES CLAIMING INTERESTS BY, THROUGH, UNDER OR AGAINST A NAMED DEFENDANT TO THIS ACTION, OR HAVING OR CLAIMING TO HAVE ANY RIGHT, TITLE OR INTEREST IN THE PROPERTY HEREIN DESCRIBED; UNKNOWN TENANT #1; UNKNOWN TENANT #2, Defendant(s). / DEFENDANTS’ RESPONSE TO FIRST REQUEST FOR ADMISSIONS COMES NOW the Defendants, WILFREDO MILAN AND LISETTE REIGOSA, (hereinafter “Defendants”), by and through undersigned counsel and pursuant to Rule 1.370, Fla. R. Civ. Pro., and hereby submits their Response to Plaintiff's Request for Admissions. Mack Law Firm Chartered £ www. MackLawFimn org 2022 Placida Road * Englewood Florida 24224-5204 < (041) 66 This pleading serves as designation of e Kawfira.org,1. Defendant Milan objects to this request and denies this request because the original wet- ink Note has not been filed with the Clerk of Court. As a result he cannot confirm that the copy attached to Plaintiffs complaint is a true and correct copy of the original wet-ink Note that he signed. Defendant has made a reasonable inquiry and can state that he did execute a Note in April, 2005, securing indebtedness of $130,500.00. 2. Defendants object to this Request because the term “genuine” is not defined. In addition, Defendant Milan objects to this request and denies this request because the original wet- ink Note has not been filed with the Clerk of Court. As a result he cannot confirm that the copy attached to Plaintiff's complaint is a true and correct copy of the original wet-ink Note that he signed. Defendant has made a reasonable inquiry and can state that he did execute a Note in April, 2005, securing indebtedness of $130,500.00. 3. Defendants object to this Request because the phrase “the Note” is not defined. In addition, Defendant Milan objects to this request and denies this request because the original wet- ink Note has not been filed with the Clerk of Court (assuming that is the Note referred to in the Request). As a result he cannot confirm that the copy attached to Plaintiffs complaint is a true and correct copy of the original wet-ink Note that he signed. Defendant has made a reasonable inquiry and can state that he did execute a Note in April, 2005, securing indebtedness of $130,500.00. 4. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion, the term “the installment” is not defined. 5. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion, the term “the installment” and the phrase “event of default” are not defined. 6. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion and the phrase “breached the terms of the note” is not defined. 7. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion and he does not know what a “Breach Letter” refers to. Mack Law Finm Chaztered w 2022 Placida Road + Englewood Florida 2422. This pleading serves as desiguation of e-serv fresses, eser chianutie Jes raacklavefiren 07g, pursue to Fla, R. Juck. Admin, 2.5168. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion. Defendant Milan has examined the Mortgage and Note and cannot find the phrase “Breach Letter” in either document. 9. Defendant Milan has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because it appears to require a legal conclusion and the term “default” is not defined. 10. Defendant has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because he is not privy to the Plaintiff's decisions. 11. Defendant has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because he thought the Note was discharged in his bankruptcy. 12. Defendant has made a reasonable inquiry and the information he knows or can readily obtain is insufficient to enable him to admit or deny this request because he thought the Note was discharged in his bankruptcy. 13. Defendants object to this Request because the phrase “the Note” is not defined. Defendants have made a reasonable inquiry and can state that they did execute a Mortgage in April, 2005, securing indebtedness of $130,500.00. 14. Defendants object to this request and deny this request because the original wet- ink Mortgage has not been filed with the Clerk of Court. As a result they cannot confirm that the copy attached to Plaintiffs complaint is a true and correct copy of the original wet-ink Mortgage that they signed. Defendants have made a reasonable inquiry and can state that they did execute a Mortgage in April, 2005. 15. Defendants object to this Request because the phrase “the Mortgage” is not defined. Defendants have made a reasonable inquiry and can state that they did execute a Mortgage in April, 2005, securing indebtedness of $130,500.00. Jacqulyn Mack-Majka, Esquire Florida bar No.: 0134902 MACK LAW FIRM CHARTERED Primary: eservicel @macklawfirm.org Mack Law Firm Chartered 4 www.MackLawFim 2022 Placida Road {+ Englewood Flosids 7 This pleading serves as designation of eservice adr nacklavfirn org,Secondary: eservice2@macklawfirm.org 2022 Placida Road Englewood, Florida 34224-5204 (941) 475-7966 (941) 475-0729 fax Attorney for Milan and Reigosa CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by e-mail to all counsel of record via the Florida Courts E-Filing Portal on January 9, 2018. /s/ Jacqulyn Mack-Majka Jacqulyn Mack-Majka, Esquire Tripp Scott, P.A. H. Michael Solloa, Jr. 110 SE 6th Street 15th floor Ft. Lauderdale, FL 33301 954-765-2918 mxs@trippscott.com Mack Law Firm Chartered 4 www.MackLawFim 2022 Placida Road {+ Englewood Flosids 75 7 This pleading serves as designation of eservice adr nacklavfirn org,