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Filing # 130376929 E-Filed 07/09/2021 03:51:02 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN AND
SUNTRUST BANK FOR BROWARD COUNTY, FLORIDA
Plaintiff,
Case No.: CACE-19-021485
VS.
JASON BURNS AKA JASON M. BURNS,
MARIBEL BURNS, UNKNOWN TENANT #1,
UNKNOWN TENANT #2, and all unknown
parties claiming an interest by, through, under
or against any Defendant, or claiming any
right, title, and interest in the subject property,
Defendants.
PLAINTIFF'S WITNESS AND EXHIBIT LISTS
The Plaintiff, TRUIST BANK, successor by merger to, SUNTRUST BANK (hereinafter
referred to as "Truist", by and through its undersigned attorneys, hereby serves the following
Witness and Exhibit Lists:
WITNESS LIST
1. Plaintiff shall call from Truist, which is located at 1 001 Semmes Avenue,
Richmond, Virginia 23224, one or more representatives with knowledge as to authenticity of
business records of the subject loan, including the Home Equity Line of Credit and Promissory
Note and mortgage, payment history, default, standing of Truist, amounts due and owing,
correspondence, signatures, rebuttal of any defenses raised by the Defendants, and any other
information relevant to the subject loan, c/o Arthur S. Barksdale IV, Esq., Alvarez, Winthrop,
Thompson & Storey, P.A., 390 N. Orange Avenue, Suite 600, Orlando, FL 32801, (407) 210-
The person(s) to be called will be
2796. This person will testify as to both liability and damages,
a Truist representative from the following list:
a. Lauren Allen, AVE Legal Proceedings Officer
b. Beverly Dumas, AVP, Legal Proceedings Officer
c. Nancy Johnson, AVP, Legal Proceedings Officer
d. Gale Valentine, AVP, Mortgage Operations Manager
e. Scout Saylors, Mediation Analyst/Paralegal
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/09/2021 03:51:02 PM.****
2. Any other parties to the lawsuit.
3. Without waiving any objections, any witness that may be listed by Defendants.
4. Rebuttal Witnesses not presently known.
EXHIBIT LIST
1. Access 3 Equity Line of Credit and Disclosure Statement dated July 25, 2016.
2. Mortgage dated July 15,2014.
3. Modification of Mortgage dated June 26, 2015.
4. Modification of Mortgage dated July 25, 2016.
5. Loan payment history.
6. Letters dated May 8,2019, to Maribel Burns.
7. Letters dated May 8, 2019, to Jason M. Burns.
8 Any and all rebuttal exhibits as necessary.
9. Any and all pleadings in this action,
10. Without waiving any objections, any exhibits listed by Defendants.
11. Without waiving any objections, any affidavits filed in this action.
Lists in the
Plaintiff reserves the right to amend or supplement these Witness and Exhibit
exhibits become known prior to trial or have inadvertently been
event additional witnesses or
omitted.
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Filing # 130376929 E-Filed 07/09/2021 03:51:02 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND SUNTRUST BANK FOR BROWARD COUNTY, FLORIDA Plaintiff, Case No.: CACE-19-021485 VS. JASON BURNS AKA JASON M. BURNS, MARIBEL BURNS, UNKNOWN TENANT #1, UNKNOWN TENANT #2, and all unknown parties claiming an interest by, through, under or against any Defendant, or claiming any right, title, and interest in the subject property, Defendants. PLAINTIFF'S WITNESS AND EXHIBIT LISTS The Plaintiff, TRUIST BANK, successor by merger to, SUNTRUST BANK (hereinafter referred to as "Truist", by and through its undersigned attorneys, hereby serves the following Witness and Exhibit Lists: WITNESS LIST 1. Plaintiff shall call from Truist, which is located at 1 001 Semmes Avenue, Richmond, Virginia 23224, one or more representatives with knowledge as to authenticity of business records of the subject loan, including the Home Equity Line of Credit and Promissory Note and mortgage, payment history, default, standing of Truist, amounts due and owing, correspondence, signatures, rebuttal of any defenses raised by the Defendants, and any other information relevant to the subject loan, c/o Arthur S. Barksdale IV, Esq., Alvarez, Winthrop, Thompson & Storey, P.A., 390 N. Orange Avenue, Suite 600, Orlando, FL 32801, (407) 210- The person(s) to be called will be 2796. This person will testify as to both liability and damages, a Truist representative from the following list: a. Lauren Allen, AVE Legal Proceedings Officer b. Beverly Dumas, AVP, Legal Proceedings Officer c. Nancy Johnson, AVP, Legal Proceedings Officer d. Gale Valentine, AVP, Mortgage Operations Manager e. Scout Saylors, Mediation Analyst/Paralegal *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 07/09/2021 03:51:02 PM.**** 2. Any other parties to the lawsuit. 3. Without waiving any objections, any witness that may be listed by Defendants. 4. Rebuttal Witnesses not presently known. EXHIBIT LIST 1. Access 3 Equity Line of Credit and Disclosure Statement dated July 25, 2016. 2. Mortgage dated July 15,2014. 3. Modification of Mortgage dated June 26, 2015. 4. Modification of Mortgage dated July 25, 2016. 5. Loan payment history. 6. Letters dated May 8,2019, to Maribel Burns. 7. Letters dated May 8, 2019, to Jason M. Burns. 8 Any and all rebuttal exhibits as necessary. 9. Any and all pleadings in this action, 10. Without waiving any objections, any exhibits listed by Defendants. 11. Without waiving any objections, any affidavits filed in this action. Lists in the Plaintiff reserves the right to amend or supplement these Witness and Exhibit exhibits become known prior to trial or have inadvertently been event additional witnesses or omitted.