Preview
Filing # 134962663 E-Filed 09/21/2021 08:59:12 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO. CACE19021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
VS.
ANDRE ST. STEVE KIFFIN, et.
al.
Defendant(s).
1
RESPONSE IN OPPOSITION TO DEFENDANT'S
MOTION FOR REHEARING
Plaintiff, FREEDOM MORTGAGE CORPORATION, by and
through its undersigned attorney, hereby files its Response in
Opposition to Defendant's Motion for Rehearing, and in support
thereof states as follows:
BACKGROUND
1. This matter arises out of a Note and Mortgage originated by
Andre St. Steve Kiffin (hereinafter the "Borrower") on April
4, 2017, for the property located at 2126 N. 32nd Avenue,
Hollywood, Florida 33021. The amount of the loan was for
$319,113.00 with the first payment due on June 1, 2017. The
loan in default as of May 1, 2019.
2. Plaintiff filed its Complaint for foreclosure of mortgage on
October 18, 2019.
1111111111111111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111111
19-376234 -
ReJ
PAGE 1
***
FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/21/2021 08:59:12 AM.****
3. On or about May 5, 2021, the Court entered an order setting
this case for trial on August 17, 2021.
4. On August 11, 2021, Plaintiff filed a Motion to Continue
Trial. On August 16, 2021, the Court denied Plaintiff's
Motion.
5. In anticipation of trial, the undersigned and the Borrower
discussed settlement. As reflected in the attached email
chain, the Borrower agreed to consent to entry of a final
judgment of foreclosure in exchange for an extended sale date.
6. Despite the fact that the Defendant did not execute and return
the consent or even appear at the trial, the Plaintiff
requested the extended sale date as part of the Final
Judgment.
7. On August 17, 2021, the Court entered a Final Judgement for
$384,699.72, with a sale date of November 16, 2021.
8. A September 2, 2021 the Defendant filed a Verified Motion for
Rehearing claiming that the Plaintiff had violated the CARES
Act by failing to have the trial cancelled.
9. On September 8, 2021, attorney, Bruce Botsford filed a Notice
of Appearance in this matter.
ARGUMENT
10. The sole purpose of a Motion for Rehearing is to give the
Trial Court an opportunity to consider matters which it failed
19-376234 -
ReJ
PAGE 2
to consider or overlooked. Diamond Cab Co. of Miami v. King,
I.
146 So. 2d. 889 (Fla. 1962). It 1S not a vehicle through
which unhappy litigant or attorney [may] reargue the same
points previously presented [.]" McDonnell v. Sanford Airport
Auth., 200 So. 3d 83, at *1 (Fla. 5th DCA 2015). The Motion
for Rehearing merely rehashes the arguments made by the
Defendants in the Motion for Summary Judgment. Thus, unless
there is some issue, which the Court overlooked or failed to
consider, which renders the judgment inequitable and
erroneous, a motion for hearing is improper. Muth v. AUI Ins.
Co., 982 So 2d 749 (Fla. 4th DCA 2008).
11. Defendant in his Motion for Rehearing is attempting to
re-argue matters previously presented to and decided by the
Court. In accordance with the standard espoused by the Florida
Supreme Court above the Motion for Rehearing is improper and
must be denied.
CONCLUSION
The Defendant's Motion is both procedurally improper and
legally insufficient. Contrary to the Borrower's assertion, this
case was not subject to a moratorium when the trial proceeded.
This is because the moratorium expired on July 31, 2021. The
Borrower also fails to acknowledge that he consented to entry of
19-376234 -
ReJ
PAGE 3
a final judgment of foreclosure and that Plaintiff made a good
faith attempt to continue the trial. Accordingly, the Court
should deny the Motion.
WHEREFORE, Plaintiff, FREEDOM MORTGAGE CORPORATION, hereby
responds in opposition to Defendant Andre St. Steve Kiffin's
Motion for Rehearing, and requests this Court deny same, and to
grant any other further relief this Court deems just and
equitable.
CERTIFICATE OF SERVICE
I hereby certify that a copy of the Response in Opposition
to Defendant(s) Andre St. Steve Kiffin's Motion for Rehearing has
been furnished to the parties listed on the attached service list
via Mail and/or E-mail in accordance with the corresponding
addresses listed therein on this 17th day of September, 2021.
ROBERTSON, ANSCHUTZ, SCHNEID, CRANE
& PARTNERS, PLLC
Attorney for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: flmail@raslg.com
By: -\S\Lourdes Sanchez Barcia-
Lourdes Sanchez Barcia,
Esquire
Florida Bar No. 598461
Communication Email:
19-376234 -
ReJ
PAGE 4
SERVICE LIST
BRUCE BOTSFORD
COUNSEL FOR ANDRE ST. STEVE KIFFIN
1615 SW 2ND AVENUE
FORT LAUDERDALE, FL 33315
PRIMARY EMAIL:
SECONDARY EMAIL:
19-376234 -
ReJ
PAGE 5
Rebecca Jimenez
From: Lourdes Sanchez-Barcia
Sent: Wednesday, August 11,2021 12:38 PM
To: 'Matthews Kiffin'
CC: Victoria Lewis
Subject: RE: RAS 19-376234 St. Kiffin Trial 08-17-2021
Attachments: 19-376234 Kiffin Consent 90 days and a waiver.pdf
Mr. Kiffin:
Attached is the consent for your review, approval and execution.
Regards,
Lourdes
786 210 5109
From: Matthews Kiffin
Sent: Wednesday, August 11, 2021 10:46 AM
To: Lourdes Sanchez-Barcia
Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021
This message originated outside of the organization. Use caution when opening attachments,clicking links or responding to
requests for information.
I am interested, yes .
Sent from my iPhone
On Aug 11, 2021, at 10:23 AM, Lourdes Sanchez-Barcia wrote:
Please let me know if you are interested in a consent to judgment in
exchange for an extended sale date of 90 days and waiver of
deficiency.
From: Matthews Kiffin
Sent: Wednesday, August 11, 2021 10:13 AM
To: Lourdes Sanchez-Barcia
Cc: Victoria Lewis
Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021
Yes I am interested in consent.
Sent from my iPhone
1
On Aug 10, 2021, at 5:47 PM, Lourdes Sanchez-Barcia
wrote:
Thank you for your response. Does this mean you are not interested in a
consent?
Sent with BlackBerry Work (www. blackberry.com)
From: Matthews Kiffin
Sent: Aug 10, 2021 5:05 PM
To: Lourdes Sanchez-Barcia
Cc: Victoria Lewis
Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021
This message originated outside of the organization. Use caution when opening
attachments, clicking links or responding to requests for information.
No counsel needed, thank you .
Sent from my iPhone
On Aug 10, 2021, at 3:42 PM, Lourdes Sanchez-Barcia
wrote:
Mr. Kiffin:
I hope you are well. It is my understanding that
you are not currently represent by counsel, if
this information is incorrect kindly provide me
the contact information for your attorney.
I am again reaching out to you on this matter as
we have a trial set for 08-17-2021. Please let
me know if you are interested in a consent to
judgment exchange in for an extended sale date of
90 days and waiver of deficiency.
I look forward to hearing from you soon.
Regards,
Lourdes
786 210 5109
2
From: Matthews Kiffin
Sent: Apr 23, 2021 7:50 AM
To: Lourdes Sanchez-Barcia
Subject: Re: RAS 19-376234 St. Kiffin Trial 05-15-2021
And if I deny ? Trying to understand my options in regards to
being able to stay in the home a few more months or if I need to
vacate sooner than later ?
On Apr 23, 2021, at 7:26 AM, Lourdes Sanchez-
Barcia wrote:
If you agree with our motion to continue the
trial then the trial maybe pushed back from the
current May 15, 2021.
Sent with
BlackBerry Work
(www.blackberry.com)
From: Matthews Kiffin
Sent: Apr 23, 2021 7:12 AM
To: Lourdes Sanchez-Barcia
Subject: Re: RAS 19-376234 St. Kiffin Trial 05-
15-2021
This message originated outside of the organization. Use
caution when opening attachments, clicking links or
responding to requests for information.
Goor morning, I don't not have representation, nor
will I be providing in the future. In regards to
accepting trial or not, exactly what's the next step if
I accept or deny ?
On Apr 22, 2021, at 1:25 PM,
Lourdes Sanchez-Barcia
wrote:
Good afternoon:
It is understanding that
my
you currently
are not
represent by counsel, if
this information is
incorrect kindly provide me
3
the contact information for
your attorney.
Please note we have filed a
motion to continue the
trial set for May 5,
2021. Kindly, advise if
you would like to present
the Court an Agreed Order
continuing the trial.
I look forward to hearing
from you soon.
Best regards,
Lourdes
786 210 5109
In some circumstancesthis firm may be deemed a
"debt collector" as defined by the Fair Debt
Collection PracticesAct and other applicablelaw.
In such a case, this is an attempt to collect a debt.
Any communicationobtained may be used for
that purpose.
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e-mail is covered by the Electronic Communications
Privacy Act, 18 U.S.C. § 2510-2521 and is legally
privileged.The contents of this e-mail message and
any attachmentsare intended solely for the party or
parties addressed and named in this message. This
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-
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communication or any attachments. Although this E-
mail and any attachments are believed to be free of
any virus or other defect that might affect any
computer system into which it is received and
opened, it is the responsibilityof the recipient to
ensure that it is virus free and no responsibilityis
accepted by Robertson, Anschutz,Schneid, Crane &
Partners, PLLC for damage arising in any way from its
use.
In some circumstancesthis firm may be deemed a "debt collector" as
defined by the Fair Debt Collection PracticesAct and other applicable
law. In such a case, this is an attempt to collect a debt. Any
communicationobtained may be used for that purpose.
PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by
the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510-2521 and is
legally privileged.The contents of this e-mail message and any attachments
are intended solely for the party or parties addressed and named in this
message. This communication and all attachments, if any, are intended to
be and to remain confidential,and it may be subjectto the applicable
attorney client and or work product privileges.If you are not the intended
-
recipient of this message, or if this message has been addressed to you in
error, please immediately alert the sender by reply e-mail and then delete
this message and its attachments. Do not deliver, distribute, or copy this
message and or any attachmentsif you are not the intended recipient. Do
not disclosethe contents or take any action in reliance upon the information
contained in this communication or any attachments. Although this E-mail
and any attachments are believed to be free of any virus or other defectthat
4
might affect any computer system into which it is received and opened, it is
the responsibilityof the recipient to ensure that it is virus free and no
responsibilityis accepted by Robertson, Anschutz,Schneid, Crane &
Partners, PLLC for damage arising in any way from its use.
Insome circumstancesthis firm may be deemed a "debt collector" as defined by the Fair
Debt Collection PracticesAct and other applicablelaw. In such a case, this is an attempt
to collect a debt. Any communicationobtained may be used for that purpose.
PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic
CommunicationsPrivacy Act, 18 U.S.C. § 2510-2521 and is legally privileged.The contents of
this e-mail message and any attachmentsare intended solely for the party or parties addressed
and named in this message. This communication and all attachments, if any, are intended to be
and to remain confidential,and it may be subject to the applicableattorney client and or work
-
product privileges.If you intended recipient of this message, or if this message has
are not the
been addressed to you in error, please immediately alert the sender by reply e-mail and then
delete this message and its attachments. Do not deliver, distribute, or copy this message and or
any attachments if you are not the intended recipient. Do not disclosethe contents or take any
action in reliance upon the information contained in this communication or any attachments.
Although this E-mail and any attachmentsare believed to be free of any virus or other defect that
might affect any computer system into which it is received and opened, it is the responsibilityof
the recipient to ensure that it is virus free and no responsibilityis accepted by Robertson,
Anschutz,Schneid, Crane & Partners, PLLC for damage arising in any way from its use.
In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection
PracticesAct and other applicable law. In such a case, this is an attempt to collect a debt. Any communication
obtained may be used for that purpose.
PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act,
18 U.S.C. § 2510-2521 and is legally privileged. The contents of this e-mail message and any attachmentsare
intended solely for the party or parties addressed and named in this message. This communication and all
attachments, if any, are intended to be and to remain confidential,and it may be subject to the applicableattorney-
client and or work product privileges. If you are not the intended recipient of this message, or if this message has been
addressed to you in error, please immediately alert the sender by reply e-mail and then deletethis message and its
attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended
recipient. Do not disclose the contents or take any action in reliance upon the informationcontained in this
communication or any attachments. Although this E-mail and any attachmentsare believed to be free of any virus or
other defectthat might affect any computersystem into which it is received and opened, it is the responsibilityof the
recipient to ensure that it is virus free and no responsibilityis accepted by Robertson,Anschutz,Schneid, Crane &
Partners, PLLC for damage arising in any way from its use.
In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other
applicablelaw. In such a case, this is an
attempt to collect a debt. Any communicationobtained may be used for that purpose.
PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510-
2521 and is
legally privileged.The contents of this e-mail message and any attachmentsare intended solely for the party or parties
addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it
may be subject to the applicableattorney client and or work product privileges.If you are not the intended recipient of this message, or if
-
this message has been addressed to you in error, please immediately alert the sender by reply e-mail and then delete this message and its
attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended recipient. Do not disclose
the contents or take any action in reliance upon the informationcontained in this communication or any attachments. Although this E-mail
and any attachments are believed to be free of any virus or other defectthat might affect any computer system into which it is received and
opened, it is the responsibilityof the recipientto ensure that it is virus free and no responsibilityis accepted by Robertson, Anschutz,
Schneid, Crane & Partners, PLLC for damage arising in any way from its use.
5
Preview
Filing # 134962663 E-Filed 09/21/2021 08:59:12 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. CACE19021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, VS. ANDRE ST. STEVE KIFFIN, et. al. Defendant(s). 1 RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION FOR REHEARING Plaintiff, FREEDOM MORTGAGE CORPORATION, by and through its undersigned attorney, hereby files its Response in Opposition to Defendant's Motion for Rehearing, and in support thereof states as follows: BACKGROUND 1. This matter arises out of a Note and Mortgage originated by Andre St. Steve Kiffin (hereinafter the "Borrower") on April 4, 2017, for the property located at 2126 N. 32nd Avenue, Hollywood, Florida 33021. The amount of the loan was for $319,113.00 with the first payment due on June 1, 2017. The loan in default as of May 1, 2019. 2. Plaintiff filed its Complaint for foreclosure of mortgage on October 18, 2019. 1111111111111111111111111111111111111111111111 11111111111111111111111111111111111111111111111111111111111111111111111111111111111111111 19-376234 - ReJ PAGE 1 *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 09/21/2021 08:59:12 AM.**** 3. On or about May 5, 2021, the Court entered an order setting this case for trial on August 17, 2021. 4. On August 11, 2021, Plaintiff filed a Motion to Continue Trial. On August 16, 2021, the Court denied Plaintiff's Motion. 5. In anticipation of trial, the undersigned and the Borrower discussed settlement. As reflected in the attached email chain, the Borrower agreed to consent to entry of a final judgment of foreclosure in exchange for an extended sale date. 6. Despite the fact that the Defendant did not execute and return the consent or even appear at the trial, the Plaintiff requested the extended sale date as part of the Final Judgment. 7. On August 17, 2021, the Court entered a Final Judgement for $384,699.72, with a sale date of November 16, 2021. 8. A September 2, 2021 the Defendant filed a Verified Motion for Rehearing claiming that the Plaintiff had violated the CARES Act by failing to have the trial cancelled. 9. On September 8, 2021, attorney, Bruce Botsford filed a Notice of Appearance in this matter. ARGUMENT 10. The sole purpose of a Motion for Rehearing is to give the Trial Court an opportunity to consider matters which it failed 19-376234 - ReJ PAGE 2 to consider or overlooked. Diamond Cab Co. of Miami v. King, I. 146 So. 2d. 889 (Fla. 1962). It 1S not a vehicle through which unhappy litigant or attorney [may] reargue the same points previously presented [.]" McDonnell v. Sanford Airport Auth., 200 So. 3d 83, at *1 (Fla. 5th DCA 2015). The Motion for Rehearing merely rehashes the arguments made by the Defendants in the Motion for Summary Judgment. Thus, unless there is some issue, which the Court overlooked or failed to consider, which renders the judgment inequitable and erroneous, a motion for hearing is improper. Muth v. AUI Ins. Co., 982 So 2d 749 (Fla. 4th DCA 2008). 11. Defendant in his Motion for Rehearing is attempting to re-argue matters previously presented to and decided by the Court. In accordance with the standard espoused by the Florida Supreme Court above the Motion for Rehearing is improper and must be denied. CONCLUSION The Defendant's Motion is both procedurally improper and legally insufficient. Contrary to the Borrower's assertion, this case was not subject to a moratorium when the trial proceeded. This is because the moratorium expired on July 31, 2021. The Borrower also fails to acknowledge that he consented to entry of 19-376234 - ReJ PAGE 3 a final judgment of foreclosure and that Plaintiff made a good faith attempt to continue the trial. Accordingly, the Court should deny the Motion. WHEREFORE, Plaintiff, FREEDOM MORTGAGE CORPORATION, hereby responds in opposition to Defendant Andre St. Steve Kiffin's Motion for Rehearing, and requests this Court deny same, and to grant any other further relief this Court deems just and equitable. CERTIFICATE OF SERVICE I hereby certify that a copy of the Response in Opposition to Defendant(s) Andre St. Steve Kiffin's Motion for Rehearing has been furnished to the parties listed on the attached service list via Mail and/or E-mail in accordance with the corresponding addresses listed therein on this 17th day of September, 2021. ROBERTSON, ANSCHUTZ, SCHNEID, CRANE & PARTNERS, PLLC Attorney for Plaintiff 6409 Congress Ave., Suite 100 Boca Raton, FL 33487 Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: flmail@raslg.com By: -\S\Lourdes Sanchez Barcia- Lourdes Sanchez Barcia, Esquire Florida Bar No. 598461 Communication Email: 19-376234 - ReJ PAGE 4 SERVICE LIST BRUCE BOTSFORD COUNSEL FOR ANDRE ST. STEVE KIFFIN 1615 SW 2ND AVENUE FORT LAUDERDALE, FL 33315 PRIMARY EMAIL: SECONDARY EMAIL: 19-376234 - ReJ PAGE 5 Rebecca Jimenez From: Lourdes Sanchez-Barcia Sent: Wednesday, August 11,2021 12:38 PM To: 'Matthews Kiffin' CC: Victoria Lewis Subject: RE: RAS 19-376234 St. Kiffin Trial 08-17-2021 Attachments: 19-376234 Kiffin Consent 90 days and a waiver.pdf Mr. Kiffin: Attached is the consent for your review, approval and execution. Regards, Lourdes 786 210 5109 From: Matthews Kiffin Sent: Wednesday, August 11, 2021 10:46 AM To: Lourdes Sanchez-Barcia Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021 This message originated outside of the organization. Use caution when opening attachments,clicking links or responding to requests for information. I am interested, yes . Sent from my iPhone On Aug 11, 2021, at 10:23 AM, Lourdes Sanchez-Barcia wrote: Please let me know if you are interested in a consent to judgment in exchange for an extended sale date of 90 days and waiver of deficiency. From: Matthews Kiffin Sent: Wednesday, August 11, 2021 10:13 AM To: Lourdes Sanchez-Barcia Cc: Victoria Lewis Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021 Yes I am interested in consent. Sent from my iPhone 1 On Aug 10, 2021, at 5:47 PM, Lourdes Sanchez-Barcia wrote: Thank you for your response. Does this mean you are not interested in a consent? Sent with BlackBerry Work (www. blackberry.com) From: Matthews Kiffin Sent: Aug 10, 2021 5:05 PM To: Lourdes Sanchez-Barcia Cc: Victoria Lewis Subject: Re: RAS 19-376234 St. Kiffin Trial 08-17-2021 This message originated outside of the organization. Use caution when opening attachments, clicking links or responding to requests for information. No counsel needed, thank you . Sent from my iPhone On Aug 10, 2021, at 3:42 PM, Lourdes Sanchez-Barcia wrote: Mr. Kiffin: I hope you are well. It is my understanding that you are not currently represent by counsel, if this information is incorrect kindly provide me the contact information for your attorney. I am again reaching out to you on this matter as we have a trial set for 08-17-2021. Please let me know if you are interested in a consent to judgment exchange in for an extended sale date of 90 days and waiver of deficiency. I look forward to hearing from you soon. Regards, Lourdes 786 210 5109 2 From: Matthews Kiffin Sent: Apr 23, 2021 7:50 AM To: Lourdes Sanchez-Barcia Subject: Re: RAS 19-376234 St. Kiffin Trial 05-15-2021 And if I deny ? Trying to understand my options in regards to being able to stay in the home a few more months or if I need to vacate sooner than later ? On Apr 23, 2021, at 7:26 AM, Lourdes Sanchez- Barcia wrote: If you agree with our motion to continue the trial then the trial maybe pushed back from the current May 15, 2021. Sent with BlackBerry Work (www.blackberry.com) From: Matthews Kiffin Sent: Apr 23, 2021 7:12 AM To: Lourdes Sanchez-Barcia Subject: Re: RAS 19-376234 St. Kiffin Trial 05- 15-2021 This message originated outside of the organization. Use caution when opening attachments, clicking links or responding to requests for information. Goor morning, I don't not have representation, nor will I be providing in the future. In regards to accepting trial or not, exactly what's the next step if I accept or deny ? On Apr 22, 2021, at 1:25 PM, Lourdes Sanchez-Barcia wrote: Good afternoon: It is understanding that my you currently are not represent by counsel, if this information is incorrect kindly provide me 3 the contact information for your attorney. Please note we have filed a motion to continue the trial set for May 5, 2021. Kindly, advise if you would like to present the Court an Agreed Order continuing the trial. I look forward to hearing from you soon. Best regards, Lourdes 786 210 5109 In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other applicablelaw. In such a case, this is an attempt to collect a debt. Any communicationobtained may be used for that purpose. PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. § 2510-2521 and is legally privileged.The contents of this e-mail message and any attachmentsare intended solely for the party or parties addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it may be subject to the applicableattorney client and or - work product privileges. If you are not the intended recipient of this message, or if this message has been addressed to you in error, please immediately alert the sender by reply e-mailand then deletethis message and its attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended recipient. Do not disclosethe contents or take any action in reliance upon the informationcontained in this communication or any attachments. Although this E- mail and any attachments are believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibilityof the recipient to ensure that it is virus free and no responsibilityis accepted by Robertson, Anschutz,Schneid, Crane & Partners, PLLC for damage arising in any way from its use. In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other applicable law. In such a case, this is an attempt to collect a debt. Any communicationobtained may be used for that purpose. PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510-2521 and is legally privileged.The contents of this e-mail message and any attachments are intended solely for the party or parties addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it may be subjectto the applicable attorney client and or work product privileges.If you are not the intended - recipient of this message, or if this message has been addressed to you in error, please immediately alert the sender by reply e-mail and then delete this message and its attachments. Do not deliver, distribute, or copy this message and or any attachmentsif you are not the intended recipient. Do not disclosethe contents or take any action in reliance upon the information contained in this communication or any attachments. Although this E-mail and any attachments are believed to be free of any virus or other defectthat 4 might affect any computer system into which it is received and opened, it is the responsibilityof the recipient to ensure that it is virus free and no responsibilityis accepted by Robertson, Anschutz,Schneid, Crane & Partners, PLLC for damage arising in any way from its use. Insome circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other applicablelaw. In such a case, this is an attempt to collect a debt. Any communicationobtained may be used for that purpose. PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510-2521 and is legally privileged.The contents of this e-mail message and any attachmentsare intended solely for the party or parties addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it may be subject to the applicableattorney client and or work - product privileges.If you intended recipient of this message, or if this message has are not the been addressed to you in error, please immediately alert the sender by reply e-mail and then delete this message and its attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended recipient. Do not disclosethe contents or take any action in reliance upon the information contained in this communication or any attachments. Although this E-mail and any attachmentsare believed to be free of any virus or other defect that might affect any computer system into which it is received and opened, it is the responsibilityof the recipient to ensure that it is virus free and no responsibilityis accepted by Robertson, Anschutz,Schneid, Crane & Partners, PLLC for damage arising in any way from its use. In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other applicable law. In such a case, this is an attempt to collect a debt. Any communication obtained may be used for that purpose. PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510-2521 and is legally privileged. The contents of this e-mail message and any attachmentsare intended solely for the party or parties addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it may be subject to the applicableattorney- client and or work product privileges. If you are not the intended recipient of this message, or if this message has been addressed to you in error, please immediately alert the sender by reply e-mail and then deletethis message and its attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended recipient. Do not disclose the contents or take any action in reliance upon the informationcontained in this communication or any attachments. Although this E-mail and any attachmentsare believed to be free of any virus or other defectthat might affect any computersystem into which it is received and opened, it is the responsibilityof the recipient to ensure that it is virus free and no responsibilityis accepted by Robertson,Anschutz,Schneid, Crane & Partners, PLLC for damage arising in any way from its use. In some circumstancesthis firm may be deemed a "debt collector" as defined by the Fair Debt Collection PracticesAct and other applicablelaw. In such a case, this is an attempt to collect a debt. Any communicationobtained may be used for that purpose. PRIVILEGE AND CONFIDENTIALITY NOTICE: This e-mail is covered by the Electronic CommunicationsPrivacy Act, 18 U.S.C. § 2510- 2521 and is legally privileged.The contents of this e-mail message and any attachmentsare intended solely for the party or parties addressed and named in this message. This communication and all attachments, if any, are intended to be and to remain confidential,and it may be subject to the applicableattorney client and or work product privileges.If you are not the intended recipient of this message, or if - this message has been addressed to you in error, please immediately alert the sender by reply e-mail and then delete this message and its attachments. Do not deliver, distribute, or copy this message and or any attachments if you are not the intended recipient. Do not disclose the contents or take any action in reliance upon the informationcontained in this communication or any attachments. Although this E-mail and any attachments are believed to be free of any virus or other defectthat might affect any computer system into which it is received and opened, it is the responsibilityof the recipientto ensure that it is virus free and no responsibilityis accepted by Robertson, Anschutz, Schneid, Crane & Partners, PLLC for damage arising in any way from its use. 5