Preview
+ FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#**
ONE STOP DIVISION
TRANSMITTAL SHEET
TO: M. AGE PROBATE CIR. CIVIL
From: , (Nor WEST RICK CASE SOUTH
SENT BY: j [ RECEIVED BY: fpACEiVvey
pate sent: Niu 2S, 201% _ pate RECEIVED: UIEieeecaee
CASE _NUMBER/NAME ITEM DESCRIPTION
dats 1922570 | Ceti fucte gy peprd
7 (13) 7 () °
3
4
5
6
7
8
9
10
1
12
13
132-15 ONE STOP DIV TRANSMITTAL SHEET10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
+ FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#**
Frances J Floyd
3550 N.W. 8th Ave #407
Pompano Beach , FL 33064
(954) 419-8801
In the Circuit Court of Florida in the
county of BROWARD
CITIBANK, N.A. )Case No.: CACE-19-022570
)
Plaintiff )CERTIFICATE OF SERVICE
)
vs. )
)
Frances J Floyd )
)
Defendant(s) )
)
CERTIFICATE OF SERVICE
I certify under penalty of perjury under the laws of the
State of Florida that, on the date stated below, I did the
following:
On the day of November 21, 2019, I mailed by Certified Mail,
Return Receipt, postage pre-paid, a true copy of the Notice
of Appearance and the Answer, Affirmative Defenses to
CITIBANK, N.A. at the offices of RAS LAVAR at the following
address: 1133 S. University Dr, , Plantation , FL 33324
Dated this November 21, 2019,
in the city of Pompano Beach ,
FL
Hare
Frances J Floyd
{Certificate of Service] - 1
SummonsResponse.com10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
#4 FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 1 1/27/2019 4:30:00 PM.****
Frances J Floyd
3550 N.W. 8th Ave #407
Pompano Beach , FL 33064
(954) 419-8801
In the Circuit Court of Florida in the
county of BROWARD
CITIBANK, N.A. )Case No.: CACE-19-022570
Plaintiff jae SE NOTICE OF APPEARANCE
vs.
Frances J Floyd
Defendant(s)
The undersigned enters an appearance in this action, and
demands notice of all further proceedings. The Clerk of
Court and the opposing party will be informed of any changes
in address. Any and all notices may be sent to:
Service Address:
3550 N.W. 8th Ave #407, Pompano Beach , FL 33064
Dated this November 21, 2019
Ayan, | Ay?
Frances J Floyd
(Notice of Appearance] - 1 : id pleepbhteceon10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
+ FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#**
Frances J Floyd
3550 N.W. 8th Ave #407
Pompano Beach , FL 33064
(954) 419-8801
In the Circuit Court of Florida in the
county of BROWARD
CITIBANK, N.A. )Case No.: CACE-19-022570
)ANSWER, AFFIRMATIVE DEFENSES
Plaintiff
vs.
Frances J Floyd
Defendant(s)
I. ANSWER
Defendant(s) answer the complaint as follows:
1. Admit the statements contained in paragraph numbers
2. Deny the statements contained in paragraph numbers 1,
2, 3, 4, 5,
3. Lack knowledge about the truth and therefore deny the
statements contained in paragraphs numbers
[Affirmative Defense] - 1
SummonsResponse.com10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
+ FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#**
II. AFFIRMATIVE DEFENSES
Defendant(s) other defenses are:
Failure of Consideration
Dated this November 21, 2019
Frances J Floyd
3550 N.W. 8th Ave #407
Pompano Beach , FL 33064
(954) 419-8801
{Affirmative Defense] - 2
SummonsResponse.com10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
**** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM,****
Frances J Floyd
3550 N.W. 8th Ave #407
Pompano Beach , FL 33064
(954) 419-8801
In the Circuit Court of Florida in the
county of BROWARD
CITIBANK, N.A. )Case No.: CACE-19-022570
)DECLARATION OF DEFENDANT Frances
Plaintiff )J Floyd REGARDING INCOME AND
)ASSETS EXEMPT FROM GARNISHMENT
vs.
Frances J Floyd
Defendant
I, Frances J Floyd , declare under penalty of perjury under
the laws of the State of Florida as follows:
1. My name is Frances J Floyd , and I am a defendant/respondent in
this lawsuit.
2. I am over the age of eighteen and am competent to testify.
3. My mailing address is: 3550 N.W. 8th Ave #407, Pompano Beach ,
FL 33064
4. My/Our source(s) of income and its exempt status, if any, is as
follows:
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 1
SummonsResponse.com10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
*#* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
0
[Xx]
01
0]
0]
0]
is)
0]
0
0]
01
0]
0
0]
01
01
0]
0)
(1
0]
My spouse's separate earnings. RCW 6.15.040; RCW 26.16.200;
Supplemental Security Income. 42 U.S.C. § 1383(d); 42 U.S.C. §
407;
Veteran’s Benefits. 38 U.S.C. § 5301;
Social Security (Disability, Retirement, Survivors). 42 U.S.C.
§ 407;
Federal Civil Service Retirement. 5 U.S.C. § 8346;
Armed Forces Savings Account. 10 U.S.C. § 1035(d);
Injury or Death Compensation from War Risk Hazards. 42 U.S.C. §
1717;
Longshore and Harbor Workers’ Compensation for Death and
Disability. 33 U.S.C. 916;
Railroad Unemployment Insurance. 45 U.S.C. § 352;
Railroad Retirement Benefits. 45 U.S.C. § 231m;
Merchant Seamen — Individuals employed on fishing or fish
processing vessels. 46 U.S.C. §11109;
Federal Title IV Student Loans. 20 U.S.C. 1095a(d);
Employee Retirement Income Security Act (ERISA) Pensions. 29
U.S.C, § 1056(d);
Work Release Earnings. RCW 72.65.060;
Judge’s Retirement Benefits. RCW 2.12.090; 2.10.180;
Crime Victim’s Compensation. RCW 7.68.070;
Proceeds from Disability Insurance. RCW 48.18.400 et.seq.;
6.15.035;
City and State Employee’s Retirement Benefits. RCW 41.44.240;
First Class City Personnel and Police Benefits. RCW 41.20.180;
41.28.240;
Fraternal Benefit Society Benefits. RCW 48.36A.180;
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 2
SummonsResponse.com10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
0]
0]
0
0]
0]
0]
{1
0
‘eek FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
State Employee’s Retirement. RCW 41.40.052;
Teacher’s Retirement. RCW 41.32.052;
Volunteer Firefighter's Retirement. RCW 41.24.240;
Washington State Patrol Retirement. RCW 43.43.310;
Funds held by the State for a child. RCW 74.13.070;
Out-of-State Income Tax on a pension or retirement plan
received in Washington State. RCW 6.15.025;
Insurance Proceeds from Exempt Property, whether in this
declaration or not. RCW 6.15.030;
Child Support Payments. RCW 6.15.010(3)(d).
Disposable earnings (earnings less deductions required by
law). ($75% of Defendant’s disposable earnings or 30 times
Federal hourly min. wage per week WHICHEVER IS GREATER). RCW
6.27.150;
Earnings necessary to support family. (50% of disposable
earnings with spouse or child; 40% if individual). RCW 6.32.250
in conjunction with RCW 6.15.150(2);
Federal pension money, whether in debtor’s possession or
deposited or loaned by debtor. (100% (exemption applies to family
if pensioner dies or absconds)). RCW 6.15.020;
Homeowner's insurance policy proceeds covering exempt
property (i.e. fire, flood etc.). RCW 6.15.030;
Unemployment compensation benefits. (100% except for debts
incurred for necessaries furnished to individual receiving
benefits during unemployment). RCW 50.40.020;
Proceeds & avails of life insurance policies on the life
of another (for example: your parent’s life insurance policy) RCW
48.18.410;
Group life insurance proceeds. RCW 48.18.420;
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 3
SummonsResponse.com10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
0]
0
0)
01
*4** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
Annuity contract benefits up to $2,500 limit per month.
RCW 48.18.430(1)(b);
Public assistance grants & payments. RCW 74.04.280 &
74.08.2100;
city employees retirement benefits. RCW 41.28.200;
Police & Firefighters retirement benefits. RCW 41.26.180
recodified as: RCW 41.26.053, RCW 41.20.180.
Stock Options or Stock Appreciation Rights. Safeco Ins.
Co. v. Skeen, 47 Wn. App. 196 (1987)
The first $16,150.00 of personal injury proceeds of the
debtor or the debtor’s dependant; 100% of pain and suffering or
compensation for financial loss and 100% of loss of future
earning except for debts incurred for necessary support of the
debtor and any dependent of the debtor. This exemption under this
subsection does not apply to the right of the state of
Washington, or any agent or assignee of the state, as a
lienholder or subrogee for medical costs paid by the state of
Washington. RCW 6.15.010(3)(f);
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 4
SummonsResponse. com10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
**** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM,****
[x]
0]
01
(x]
(X]
(x]
0]
0
0]
I/We own the following property which is exempt from debt
collection under the following statutes (mark all that apply):
Homestead (house or mobile home where I live and any
underlying accessories and land) which is no more than $40,000
before July 22, 2007 or no more than $125,000 after July 22, 2007
in equity or total value. RCW 6.13.010; 6.13.030;
Clothing. RCW 6.15.010(1);
Furs, jewelry or personal ornaments (less than $1,000.00
in value for each item). RCW 6.15.010(1);
Private Library worth no more than $1,500.00. RCW
6.15.010(2);
Family pictures and keepsakes. RCW 6.15.010(2);
Household goods, appliances, furniture, yard equipment,
provisions and fuel up to $2,700.00 in value per person, not to
total more than $5,400 per couple. RCW 6.15.010(3) (a);
Other Personal Property, not specifically listed here, up
to $2000.00 in value with $200.00 limit on cash, bank accounts &
securities. RCW 6.15.010(3)(b);
Two motor vehicles used for personal transportation up to
$2,500.00 in value each, not more than $5,000 per couple. RCW
6.15.010(3)(c);
Farm trucks, stock, tools, equipment, supplies and seed up
to $5000.00. RCW 6.15.010(4)(a);
All professionally prescribed health aids for the debtor
or a dependent of the debtor. RCW 6.15.010(3)(e);
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 5
SummonsResponse.comuo kB Ww N
10
il
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
*#* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
() Library & office furniture, equipment & supplies of
physician, attorney, clergyman, or other professional person up
to $5,000. RCW 6.15.010(4)(b);
(] Tools, instruments & materials used to carry on trade for
support of debtor & family up to $5,000. RCW 6.15.010(4)(c);
0] Personal or family burying grounds. RCW 68.24.220 &
68.20.120;
Dated this November 21, 2019
Gore | th
Frances J Floyd
[Declaration of Defendant Regarding Income
and Assets Exempt from Garnishment] - 6
SummonsResponse.com##* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
Case Number: CACE-19-022570 Division: 13
Filing #.98168092 E-Filed 10/31/2019 11:22:55 AM
IN THE CIRCUIT COURT FOR THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA.
CASE NUMBER:
CITIBANK N.A. ,
Plaintiff, Floriga Statute 48.634 (5)
vs. Daten y [ee Time GY c
{.D./BADGEFAA Ag _INITIA\ =
FRANCES J FLOYD, MARRIED (Y) (N) MILITARY (Y) (N)
Defendant.
/
SUMMONS
PERSONAL SERVICE ON A NATURAL PERSON
THE STATE OF FLORIDA:
To Each Sheriff of the State:
YOU ARE COMMANDED to serve this summons and a copy of the complaint in this lawsuit on
FRANCES J FLOYD
3550 NW 8TH AVE APT 407
POMPANO BEACH FL 33064-3016
DATEDON OCT 31 2019
IMPORTANT BRENDA D. FORMAN
A lawsuit has been filed against you. You have 20 calendar days after this Summons is served on
you to file a written response to the attached Complaint with the Clerk of this Court. A phone call will not
protect you. Your written response, including the case number given above and the names of the Parties,
must be filed if you want the Court to hear your side of the case. If you do not file your response on time,
you may lose the case, and your wages, money, and property may thereafter be taken without further
waming from the Court. There are other legal requirements. You may want to call an attomey right away.
If you do not know an attomey, you may call an attorney referral service or a legal aid office (listed in the
phone book).
Ifyou choose to file a written response yourself, at the same time you file your written response to
the Court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney”
named below:
RAS LaVrar, LLC
1133 S. University Drive, 2nd Floor
Plantation, FL 33324
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 11:22:55 AM.****“«* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
Income from Social Security. $1,615
Retirement. 212
401k has $22,000.00
No other income
Only asset is 2010 VW Jetta with 70k miles
Rent. 750.
Home insurance .12
Electric. 100
Car Ins. 96
Internet. 60
Phone. 100
Health insurance 150
Medication. 40
Roomstogo. 50
Food. 250
Gas. 30*4** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.****
IN THE CIRCUIT COURT FOR THE 17TH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY,
FLORIDA
CASE NUMBER:
CITIBANK N.A.,
Plaintiff,
vs.
FRANCES J FLOYD,
Defendant.
/
COMPLAINT
The Plaintiff sues the Defendant and alleges:
COUNT I- ACCOUNT STATED
1. This is an action for damages which exceed $15,000.00.
2. The Defendant made purchases of various and diverse consumer goods and/or effected cash advances
through the use of a THE HOME DEPOT credit account obtained from the Plaintiff on account number
XXXXXXXXKXKX8954,
3. Before the institution of this action Plaintiff and Defendant had business transactions between them and
they agreed to the resulting balance.
4, Plaintiff rendered a statement of account to Defendant and Defendant did not object to the statement.
5. Defendant owes the Plaintiff $16014.14 that is due.
WHEREFORE, Plaintiff demands judgment against the Defendant(s) for damages of $16014.14,
court costs, and any other relief this court deems just and proper.
Ss{ Flynn LaVrar, Esq.
Flynn LaVrar, Esq., FL Bar #91596
Drew Linen, Esq., FL Bar #121577
Andres Montero, Esq., FL Bar #1018340
RAS LaVrar, LLC
ATTORNEYS FOR PLAINTIFF
1133 S. University Drive, 2nd Floor
Plantation, FL 33324
954-735-4455 or 800-531-5490
954-735-0227 (fax)
844-384-6768 (TTY)
service@raslavrar.com
File #: 3000760792
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
Preview
+ FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#** ONE STOP DIVISION TRANSMITTAL SHEET TO: M. AGE PROBATE CIR. CIVIL From: , (Nor WEST RICK CASE SOUTH SENT BY: j [ RECEIVED BY: fpACEiVvey pate sent: Niu 2S, 201% _ pate RECEIVED: UIEieeecaee CASE _NUMBER/NAME ITEM DESCRIPTION dats 1922570 | Ceti fucte gy peprd 7 (13) 7 () ° 3 4 5 6 7 8 9 10 1 12 13 132-15 ONE STOP DIV TRANSMITTAL SHEET10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 + FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#** Frances J Floyd 3550 N.W. 8th Ave #407 Pompano Beach , FL 33064 (954) 419-8801 In the Circuit Court of Florida in the county of BROWARD CITIBANK, N.A. )Case No.: CACE-19-022570 ) Plaintiff )CERTIFICATE OF SERVICE ) vs. ) ) Frances J Floyd ) ) Defendant(s) ) ) CERTIFICATE OF SERVICE I certify under penalty of perjury under the laws of the State of Florida that, on the date stated below, I did the following: On the day of November 21, 2019, I mailed by Certified Mail, Return Receipt, postage pre-paid, a true copy of the Notice of Appearance and the Answer, Affirmative Defenses to CITIBANK, N.A. at the offices of RAS LAVAR at the following address: 1133 S. University Dr, , Plantation , FL 33324 Dated this November 21, 2019, in the city of Pompano Beach , FL Hare Frances J Floyd {Certificate of Service] - 1 SummonsResponse.com10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 #4 FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 1 1/27/2019 4:30:00 PM.**** Frances J Floyd 3550 N.W. 8th Ave #407 Pompano Beach , FL 33064 (954) 419-8801 In the Circuit Court of Florida in the county of BROWARD CITIBANK, N.A. )Case No.: CACE-19-022570 Plaintiff jae SE NOTICE OF APPEARANCE vs. Frances J Floyd Defendant(s) The undersigned enters an appearance in this action, and demands notice of all further proceedings. The Clerk of Court and the opposing party will be informed of any changes in address. Any and all notices may be sent to: Service Address: 3550 N.W. 8th Ave #407, Pompano Beach , FL 33064 Dated this November 21, 2019 Ayan, | Ay? Frances J Floyd (Notice of Appearance] - 1 : id pleepbhteceon10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 + FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#** Frances J Floyd 3550 N.W. 8th Ave #407 Pompano Beach , FL 33064 (954) 419-8801 In the Circuit Court of Florida in the county of BROWARD CITIBANK, N.A. )Case No.: CACE-19-022570 )ANSWER, AFFIRMATIVE DEFENSES Plaintiff vs. Frances J Floyd Defendant(s) I. ANSWER Defendant(s) answer the complaint as follows: 1. Admit the statements contained in paragraph numbers 2. Deny the statements contained in paragraph numbers 1, 2, 3, 4, 5, 3. Lack knowledge about the truth and therefore deny the statements contained in paragraphs numbers [Affirmative Defense] - 1 SummonsResponse.com10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 + FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.*#** II. AFFIRMATIVE DEFENSES Defendant(s) other defenses are: Failure of Consideration Dated this November 21, 2019 Frances J Floyd 3550 N.W. 8th Ave #407 Pompano Beach , FL 33064 (954) 419-8801 {Affirmative Defense] - 2 SummonsResponse.com10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM,**** Frances J Floyd 3550 N.W. 8th Ave #407 Pompano Beach , FL 33064 (954) 419-8801 In the Circuit Court of Florida in the county of BROWARD CITIBANK, N.A. )Case No.: CACE-19-022570 )DECLARATION OF DEFENDANT Frances Plaintiff )J Floyd REGARDING INCOME AND )ASSETS EXEMPT FROM GARNISHMENT vs. Frances J Floyd Defendant I, Frances J Floyd , declare under penalty of perjury under the laws of the State of Florida as follows: 1. My name is Frances J Floyd , and I am a defendant/respondent in this lawsuit. 2. I am over the age of eighteen and am competent to testify. 3. My mailing address is: 3550 N.W. 8th Ave #407, Pompano Beach , FL 33064 4. My/Our source(s) of income and its exempt status, if any, is as follows: [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 1 SummonsResponse.com10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 *#* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** 0 [Xx] 01 0] 0] 0] is) 0] 0 0] 01 0] 0 0] 01 01 0] 0) (1 0] My spouse's separate earnings. RCW 6.15.040; RCW 26.16.200; Supplemental Security Income. 42 U.S.C. § 1383(d); 42 U.S.C. § 407; Veteran’s Benefits. 38 U.S.C. § 5301; Social Security (Disability, Retirement, Survivors). 42 U.S.C. § 407; Federal Civil Service Retirement. 5 U.S.C. § 8346; Armed Forces Savings Account. 10 U.S.C. § 1035(d); Injury or Death Compensation from War Risk Hazards. 42 U.S.C. § 1717; Longshore and Harbor Workers’ Compensation for Death and Disability. 33 U.S.C. 916; Railroad Unemployment Insurance. 45 U.S.C. § 352; Railroad Retirement Benefits. 45 U.S.C. § 231m; Merchant Seamen — Individuals employed on fishing or fish processing vessels. 46 U.S.C. §11109; Federal Title IV Student Loans. 20 U.S.C. 1095a(d); Employee Retirement Income Security Act (ERISA) Pensions. 29 U.S.C, § 1056(d); Work Release Earnings. RCW 72.65.060; Judge’s Retirement Benefits. RCW 2.12.090; 2.10.180; Crime Victim’s Compensation. RCW 7.68.070; Proceeds from Disability Insurance. RCW 48.18.400 et.seq.; 6.15.035; City and State Employee’s Retirement Benefits. RCW 41.44.240; First Class City Personnel and Police Benefits. RCW 41.20.180; 41.28.240; Fraternal Benefit Society Benefits. RCW 48.36A.180; [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 2 SummonsResponse.com10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 0] 0] 0 0] 0] 0] {1 0 ‘eek FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** State Employee’s Retirement. RCW 41.40.052; Teacher’s Retirement. RCW 41.32.052; Volunteer Firefighter's Retirement. RCW 41.24.240; Washington State Patrol Retirement. RCW 43.43.310; Funds held by the State for a child. RCW 74.13.070; Out-of-State Income Tax on a pension or retirement plan received in Washington State. RCW 6.15.025; Insurance Proceeds from Exempt Property, whether in this declaration or not. RCW 6.15.030; Child Support Payments. RCW 6.15.010(3)(d). Disposable earnings (earnings less deductions required by law). ($75% of Defendant’s disposable earnings or 30 times Federal hourly min. wage per week WHICHEVER IS GREATER). RCW 6.27.150; Earnings necessary to support family. (50% of disposable earnings with spouse or child; 40% if individual). RCW 6.32.250 in conjunction with RCW 6.15.150(2); Federal pension money, whether in debtor’s possession or deposited or loaned by debtor. (100% (exemption applies to family if pensioner dies or absconds)). RCW 6.15.020; Homeowner's insurance policy proceeds covering exempt property (i.e. fire, flood etc.). RCW 6.15.030; Unemployment compensation benefits. (100% except for debts incurred for necessaries furnished to individual receiving benefits during unemployment). RCW 50.40.020; Proceeds & avails of life insurance policies on the life of another (for example: your parent’s life insurance policy) RCW 48.18.410; Group life insurance proceeds. RCW 48.18.420; [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 3 SummonsResponse.com10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 0] 0 0) 01 *4** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** Annuity contract benefits up to $2,500 limit per month. RCW 48.18.430(1)(b); Public assistance grants & payments. RCW 74.04.280 & 74.08.2100; city employees retirement benefits. RCW 41.28.200; Police & Firefighters retirement benefits. RCW 41.26.180 recodified as: RCW 41.26.053, RCW 41.20.180. Stock Options or Stock Appreciation Rights. Safeco Ins. Co. v. Skeen, 47 Wn. App. 196 (1987) The first $16,150.00 of personal injury proceeds of the debtor or the debtor’s dependant; 100% of pain and suffering or compensation for financial loss and 100% of loss of future earning except for debts incurred for necessary support of the debtor and any dependent of the debtor. This exemption under this subsection does not apply to the right of the state of Washington, or any agent or assignee of the state, as a lienholder or subrogee for medical costs paid by the state of Washington. RCW 6.15.010(3)(f); [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 4 SummonsResponse. com10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 **** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM,**** [x] 0] 01 (x] (X] (x] 0] 0 0] I/We own the following property which is exempt from debt collection under the following statutes (mark all that apply): Homestead (house or mobile home where I live and any underlying accessories and land) which is no more than $40,000 before July 22, 2007 or no more than $125,000 after July 22, 2007 in equity or total value. RCW 6.13.010; 6.13.030; Clothing. RCW 6.15.010(1); Furs, jewelry or personal ornaments (less than $1,000.00 in value for each item). RCW 6.15.010(1); Private Library worth no more than $1,500.00. RCW 6.15.010(2); Family pictures and keepsakes. RCW 6.15.010(2); Household goods, appliances, furniture, yard equipment, provisions and fuel up to $2,700.00 in value per person, not to total more than $5,400 per couple. RCW 6.15.010(3) (a); Other Personal Property, not specifically listed here, up to $2000.00 in value with $200.00 limit on cash, bank accounts & securities. RCW 6.15.010(3)(b); Two motor vehicles used for personal transportation up to $2,500.00 in value each, not more than $5,000 per couple. RCW 6.15.010(3)(c); Farm trucks, stock, tools, equipment, supplies and seed up to $5000.00. RCW 6.15.010(4)(a); All professionally prescribed health aids for the debtor or a dependent of the debtor. RCW 6.15.010(3)(e); [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 5 SummonsResponse.comuo kB Ww N 10 il 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 *#* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** () Library & office furniture, equipment & supplies of physician, attorney, clergyman, or other professional person up to $5,000. RCW 6.15.010(4)(b); (] Tools, instruments & materials used to carry on trade for support of debtor & family up to $5,000. RCW 6.15.010(4)(c); 0] Personal or family burying grounds. RCW 68.24.220 & 68.20.120; Dated this November 21, 2019 Gore | th Frances J Floyd [Declaration of Defendant Regarding Income and Assets Exempt from Garnishment] - 6 SummonsResponse.com##* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** Case Number: CACE-19-022570 Division: 13 Filing #.98168092 E-Filed 10/31/2019 11:22:55 AM IN THE CIRCUIT COURT FOR THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA. CASE NUMBER: CITIBANK N.A. , Plaintiff, Floriga Statute 48.634 (5) vs. Daten y [ee Time GY c {.D./BADGEFAA Ag _INITIA\ = FRANCES J FLOYD, MARRIED (Y) (N) MILITARY (Y) (N) Defendant. / SUMMONS PERSONAL SERVICE ON A NATURAL PERSON THE STATE OF FLORIDA: To Each Sheriff of the State: YOU ARE COMMANDED to serve this summons and a copy of the complaint in this lawsuit on FRANCES J FLOYD 3550 NW 8TH AVE APT 407 POMPANO BEACH FL 33064-3016 DATEDON OCT 31 2019 IMPORTANT BRENDA D. FORMAN A lawsuit has been filed against you. You have 20 calendar days after this Summons is served on you to file a written response to the attached Complaint with the Clerk of this Court. A phone call will not protect you. Your written response, including the case number given above and the names of the Parties, must be filed if you want the Court to hear your side of the case. If you do not file your response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further waming from the Court. There are other legal requirements. You may want to call an attomey right away. If you do not know an attomey, you may call an attorney referral service or a legal aid office (listed in the phone book). Ifyou choose to file a written response yourself, at the same time you file your written response to the Court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney” named below: RAS LaVrar, LLC 1133 S. University Drive, 2nd Floor Plantation, FL 33324 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 10/31/2019 11:22:55 AM.****“«* FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** Income from Social Security. $1,615 Retirement. 212 401k has $22,000.00 No other income Only asset is 2010 VW Jetta with 70k miles Rent. 750. Home insurance .12 Electric. 100 Car Ins. 96 Internet. 60 Phone. 100 Health insurance 150 Medication. 40 Roomstogo. 50 Food. 250 Gas. 30*4** FILED: BROWARD COUNTY, FL Brenda D. Forman, CLERK 11/27/2019 4:30:00 PM.**** IN THE CIRCUIT COURT FOR THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NUMBER: CITIBANK N.A., Plaintiff, vs. FRANCES J FLOYD, Defendant. / COMPLAINT The Plaintiff sues the Defendant and alleges: COUNT I- ACCOUNT STATED 1. This is an action for damages which exceed $15,000.00. 2. The Defendant made purchases of various and diverse consumer goods and/or effected cash advances through the use of a THE HOME DEPOT credit account obtained from the Plaintiff on account number XXXXXXXXKXKX8954, 3. Before the institution of this action Plaintiff and Defendant had business transactions between them and they agreed to the resulting balance. 4, Plaintiff rendered a statement of account to Defendant and Defendant did not object to the statement. 5. Defendant owes the Plaintiff $16014.14 that is due. WHEREFORE, Plaintiff demands judgment against the Defendant(s) for damages of $16014.14, court costs, and any other relief this court deems just and proper. Ss{ Flynn LaVrar, Esq. Flynn LaVrar, Esq., FL Bar #91596 Drew Linen, Esq., FL Bar #121577 Andres Montero, Esq., FL Bar #1018340 RAS LaVrar, LLC ATTORNEYS FOR PLAINTIFF 1133 S. University Drive, 2nd Floor Plantation, FL 33324 954-735-4455 or 800-531-5490 954-735-0227 (fax) 844-384-6768 (TTY) service@raslavrar.com File #: 3000760792 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.