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Filing # 119285036 E-Filed 01/08/2021 10:39:59 AM
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL
CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE19021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
vs.
ANDRE ST. STEVE KIFFIN, et al.
Defendant(s).
/
PLAINTIFF’S TRIAL WITNESS AND EXHIBIT LIST
COMES NOW the Plaintiff, FREEDOM MORTGAGE CORPORATION, by and
through its undersigned counsel, and files this Witness and Exhibit List for Trial, and states as
follows:
WITNESS LIST
Tanya Tarver, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o Plaintiff's
Counsel, may testify as to the business records of the Plaintiff and how those records are
kept and maintained in the normal course of Plaintiff's business. Representative of Plaintiff
may also testify as to the fact that a default occurred and the amounts due and owing, and the
representative will also testify as to Plaintiff’s standing to bring the subject action and as to
the origination, processing, and servicing of Defendant’s loan and Plaintiff's business
records.
John Gresham, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o Plaintiffs
Counsel, may testify as to the business records of the Plaintiff and how those records are
kept and maintained in the normal course of Plaintiff's business. Representative of Plaintiff
may also testify as to the fact that a default occurred and the amounts due and owing, and the
representative will also testify as to Plaintiff’s standing to bring the subject action and as to
the origination, processing, and servicing of Defendant’s loan and Plaintiff's business
records.
Alberto Pereda, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o
Plaintiff's Counsel, may testify as to the business records of the Plaintiff and how those
QUA AAT HIV AAA
19-376234 - ViL
PAGE 1
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/08/2021 10:39:59 AM.*##*
records are kept and maintained in the normal course of Plaintiff's business. Representative
of Plaintiff may also testify as to the fact that a default occurred and the amounts due and
owing, and the representative will also testify as to Plaintiff's standing to bring the subject
action and as to the origination, processing, and servicing of Defendant’s loan and Plaintiffs
business records.
Other representatives on behalf of Plaintiff competent to testify in this matter.
All witnesses listed by the Defendant(s).
The remaining Defendant(s).
Any person(s) listed on the Note, Mortgage and Assignment of Mortgage.
Plaintiffs Attorney fee expert.
Any rebuttal or impeachment witnesses.
10. The Plaintiff reserves the right to call any witness listed and/or called by any other party and
reserves the right to supplement this Witness List with additional witnesses as they become
known or necessary, upon proper notice to the other parties.
EXHIBIT LIST
Note, endorsements and allonges
Bailee Letter, if applicable
Document Tracker, if applicable
Mortgage
Mortgage Loan Schedule, if applicable
Hello/Goodbye Letter, if applicable
Assignment of Mortgage, if applicable
Copy of Notice of Intent to Foreclose sent to borrower
19-376234 - ViL
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Records as to amounts due and owing, pursuant to the Note and Mortgage, including but not
limited to loan payment histories, amortization schedules, taxes and insurance escrow
payment histories and all correspondences related thereto.
10. Pooling & Service Agreement if applicable
11 Power of Attorney if applicable
12. Collection Notes, if applicable
13. Screen Shots, if applicable
14. Return Receipts, if applicable
15. Quit Claim / Warranty Deeds if applicable
16. Public Record if applicable
17. Origination file and documents contained therein if applicable
18 Certificates of incorporation, name change and/or merger if applicable
19. SEC Form 8-k if applicable
20. Servicer system screen shots
21 Affidavit of Time, Effort and Costs
22. Affidavit as to Reasonableness of Attorneys’ Fees
23 Affidavit of Indebtedness
24. All documents listed by Defendant
25 All pleadings and attachments/exhibits thereto
26. All discovery and attachments/exhibits thereto.
27. Rebuttal and impeachment exhibits
28 Any and all correspondence between the parties and communication histories.
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29. HUD-1 Settlement Statement
30. Title Policies
31 Title Commitments
32. Loan Application
33 Loan Origination Documents
34. HOA/COA Declaration of Covenants
35 Deed(s)
36. The Plaintiff reserves the right to utilize any exhibit listed by any other party and further
reserves the right to supplement this Exhibit List with additional exhibits as they become
known and/or necessary, upon proper notice to the other parties.
37. The Plaintiff reserves the right to supplement this Exhibit List.
19-376234 - ViL
PAGE 4
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the foregoing was emailed and/or
mailed on this 7 day of January, 2021, to the attached service list.
ROBERTSON, ANSCHUTZ, SCHNEID, CRANE
& PARTNERS, PLLC
Attomey for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: mail@raslg.com
By: _\S\Lourdes Sanchez Barcia_
Lourdes Sanchez Barcia, Esquire
Florida Bar No. 598461
Communication Email:
lsanchezbarcia@raslg.com
SERVICE LIST
ANDRE ST. STEVE KIFFIN
2126 N 32ND AVE
HOLLYWOOD, FL 33021
19-376234 - ViL
PAGE 5
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Filing # 119285036 E-Filed 01/08/2021 10:39:59 AM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE19021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, vs. ANDRE ST. STEVE KIFFIN, et al. Defendant(s). / PLAINTIFF’S TRIAL WITNESS AND EXHIBIT LIST COMES NOW the Plaintiff, FREEDOM MORTGAGE CORPORATION, by and through its undersigned counsel, and files this Witness and Exhibit List for Trial, and states as follows: WITNESS LIST Tanya Tarver, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o Plaintiff's Counsel, may testify as to the business records of the Plaintiff and how those records are kept and maintained in the normal course of Plaintiff's business. Representative of Plaintiff may also testify as to the fact that a default occurred and the amounts due and owing, and the representative will also testify as to Plaintiff’s standing to bring the subject action and as to the origination, processing, and servicing of Defendant’s loan and Plaintiff's business records. John Gresham, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o Plaintiffs Counsel, may testify as to the business records of the Plaintiff and how those records are kept and maintained in the normal course of Plaintiff's business. Representative of Plaintiff may also testify as to the fact that a default occurred and the amounts due and owing, and the representative will also testify as to Plaintiff’s standing to bring the subject action and as to the origination, processing, and servicing of Defendant’s loan and Plaintiff's business records. Alberto Pereda, Freedom Mortgage Corporation, as Representative of Plaintiff, c/o Plaintiff's Counsel, may testify as to the business records of the Plaintiff and how those QUA AAT HIV AAA 19-376234 - ViL PAGE 1 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 01/08/2021 10:39:59 AM.*##* records are kept and maintained in the normal course of Plaintiff's business. Representative of Plaintiff may also testify as to the fact that a default occurred and the amounts due and owing, and the representative will also testify as to Plaintiff's standing to bring the subject action and as to the origination, processing, and servicing of Defendant’s loan and Plaintiffs business records. Other representatives on behalf of Plaintiff competent to testify in this matter. All witnesses listed by the Defendant(s). The remaining Defendant(s). Any person(s) listed on the Note, Mortgage and Assignment of Mortgage. Plaintiffs Attorney fee expert. Any rebuttal or impeachment witnesses. 10. The Plaintiff reserves the right to call any witness listed and/or called by any other party and reserves the right to supplement this Witness List with additional witnesses as they become known or necessary, upon proper notice to the other parties. EXHIBIT LIST Note, endorsements and allonges Bailee Letter, if applicable Document Tracker, if applicable Mortgage Mortgage Loan Schedule, if applicable Hello/Goodbye Letter, if applicable Assignment of Mortgage, if applicable Copy of Notice of Intent to Foreclose sent to borrower 19-376234 - ViL PAGE 2 Records as to amounts due and owing, pursuant to the Note and Mortgage, including but not limited to loan payment histories, amortization schedules, taxes and insurance escrow payment histories and all correspondences related thereto. 10. Pooling & Service Agreement if applicable 11 Power of Attorney if applicable 12. Collection Notes, if applicable 13. Screen Shots, if applicable 14. Return Receipts, if applicable 15. Quit Claim / Warranty Deeds if applicable 16. Public Record if applicable 17. Origination file and documents contained therein if applicable 18 Certificates of incorporation, name change and/or merger if applicable 19. SEC Form 8-k if applicable 20. Servicer system screen shots 21 Affidavit of Time, Effort and Costs 22. Affidavit as to Reasonableness of Attorneys’ Fees 23 Affidavit of Indebtedness 24. All documents listed by Defendant 25 All pleadings and attachments/exhibits thereto 26. All discovery and attachments/exhibits thereto. 27. Rebuttal and impeachment exhibits 28 Any and all correspondence between the parties and communication histories. 19-376234 - ViL PAGE 3 29. HUD-1 Settlement Statement 30. Title Policies 31 Title Commitments 32. Loan Application 33 Loan Origination Documents 34. HOA/COA Declaration of Covenants 35 Deed(s) 36. The Plaintiff reserves the right to utilize any exhibit listed by any other party and further reserves the right to supplement this Exhibit List with additional exhibits as they become known and/or necessary, upon proper notice to the other parties. 37. The Plaintiff reserves the right to supplement this Exhibit List. 19-376234 - ViL PAGE 4 CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the foregoing was emailed and/or mailed on this 7 day of January, 2021, to the attached service list. ROBERTSON, ANSCHUTZ, SCHNEID, CRANE & PARTNERS, PLLC Attomey for Plaintiff 6409 Congress Ave., Suite 100 Boca Raton, FL 33487 Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: mail@raslg.com By: _\S\Lourdes Sanchez Barcia_ Lourdes Sanchez Barcia, Esquire Florida Bar No. 598461 Communication Email: lsanchezbarcia@raslg.com SERVICE LIST ANDRE ST. STEVE KIFFIN 2126 N 32ND AVE HOLLYWOOD, FL 33021 19-376234 - ViL PAGE 5