On October 18, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Freedom Mortgage Corporation,
and
Kiffin, Andre St Steve,
for Real Prop Non-Homestead Res Fore =/>$250,000
in the District Court of Broward County.
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Filing # 104185916 E-Filed 03/02/2020 03:28:14 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. CACE-19-021666
FREEDOM MORTGAGE CORPORATION,
Plaintiff,
vs.
ANDRE ST. STEVE KIFFIN, et. al.
Defendant (s),
/
RESPONSE TO DEFENDANT, ANDRE ST STEVE KIFFIN'S MOTION TO CONTINUE
TRIAL SET FOR MARCH 4, 2020
Plaintiff, FREEDOM MORTGAGE CORPORATION, by and through the
undersigned attorney hereby files this Response in Opposition to
Defendant, ANDRE ST STEVE KIFFIN'S MOTION TO CONTINUE TRIAL SET FOR
MARCH 4, 2020, and in support states as follows:
1 This matter arises out of a foreclosure action filed on October
18, 2019.
The Defendant, Kiffin was served November 4, 2019.
A judicial default was entered against Defendant, Kiffin on
December 6, 2019.
Defendant filed a Motion to Set Aside Order on Plaintiff’s Motion
for Judicial Default on February 28, 2019.
On or about December 13, 2019, a Trial Order was dated and signed
setting this case for Trial on March 4, 2020 at 9:00am.
IIA AA MIVA AANA
19-376234 - Mal
PAGE 1
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/02/2020 03:28:14 PM.**#*
6. The Plaintiff does not have a complete loss mitigation package on
this loan.
WHEREFORE, the Plaintiff respectfully responds to Defendant's
Motion to Continue.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the
foregoing 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 2nd day of March, 2020.
ROBERTSON, ANSCHUTZ & SCHNEID, P.L.
Attorney for Plaintiff
6409 Congress Ave., Suite
100
Boca FL 33487
Raton,
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: mail@rasflaw.com
By: Lourdes M. Sanchez-Barcia, Esq.
Lourdes Sanchez Barcia, Esquire
Florida Bar No. 598461
Email: lsanchezbarcia@rasflaw.com
19-376234 - Mal
PAGE 2
SERVICE LIST
MATOS LEGAL, PLLC
ROSALIND J. MATOS, ESQ.
ATTORNEY FOR ANDRE ST. STEVE KIFFIN
C/O MATOS LEGAL, PLLC
2645 EXECTUTIVE PARK DR. #676
WESTON, FL 33331
PRIMARY EMAIL: ROSALIND@MATOSLEGAL.COM
19-376234 - Mal
PAGE 3
Category
Real Prop Non-Homestead Res Fore =/>$250,000
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Filing # 104185916 E-Filed 03/02/2020 03:28:14 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO. CACE-19-021666 FREEDOM MORTGAGE CORPORATION, Plaintiff, vs. ANDRE ST. STEVE KIFFIN, et. al. Defendant (s), / RESPONSE TO DEFENDANT, ANDRE ST STEVE KIFFIN'S MOTION TO CONTINUE TRIAL SET FOR MARCH 4, 2020 Plaintiff, FREEDOM MORTGAGE CORPORATION, by and through the undersigned attorney hereby files this Response in Opposition to Defendant, ANDRE ST STEVE KIFFIN'S MOTION TO CONTINUE TRIAL SET FOR MARCH 4, 2020, and in support states as follows: 1 This matter arises out of a foreclosure action filed on October 18, 2019. The Defendant, Kiffin was served November 4, 2019. A judicial default was entered against Defendant, Kiffin on December 6, 2019. Defendant filed a Motion to Set Aside Order on Plaintiff’s Motion for Judicial Default on February 28, 2019. On or about December 13, 2019, a Trial Order was dated and signed setting this case for Trial on March 4, 2020 at 9:00am. IIA AA MIVA AANA 19-376234 - Mal PAGE 1 #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/02/2020 03:28:14 PM.**#* 6. The Plaintiff does not have a complete loss mitigation package on this loan. WHEREFORE, the Plaintiff respectfully responds to Defendant's Motion to Continue. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing 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 2nd day of March, 2020. ROBERTSON, ANSCHUTZ & SCHNEID, P.L. Attorney for Plaintiff 6409 Congress Ave., Suite 100 Boca FL 33487 Raton, Telephone: 561-241-6901 Facsimile: 561-997-6909 Service Email: mail@rasflaw.com By: Lourdes M. Sanchez-Barcia, Esq. Lourdes Sanchez Barcia, Esquire Florida Bar No. 598461 Email: lsanchezbarcia@rasflaw.com 19-376234 - Mal PAGE 2 SERVICE LIST MATOS LEGAL, PLLC ROSALIND J. MATOS, ESQ. ATTORNEY FOR ANDRE ST. STEVE KIFFIN C/O MATOS LEGAL, PLLC 2645 EXECTUTIVE PARK DR. #676 WESTON, FL 33331 PRIMARY EMAIL: ROSALIND@MATOSLEGAL.COM 19-376234 - Mal PAGE 3