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Filing # 99770845 E-Filed 12/04/2019 11:40:18 AM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT OF
FLORIDA IN AND FOR BROWARD COUNTY
GENERAL JURISDICTION DIVISION
CASE NO. CACE-19-021666
FREEDOM MORTGAGE
CORPORATION,
Plaintiff,
vs.
ANDRE ST. STEVE KIFFIN, et. al.
Defendant(s),
/
AFFIDAVIT AS TO NON-MILITARY STATUS
STATE OF FLORIDA
COUNTY OF PALM BEACH
1 I, Lindsay Yarmuth, am at least eighteen (18) years of age and legally competent to execute
this Affidavit.
Tam the attorney of record for Plaintiff in this action and am authorized to make this affidavit
and have personal knowledge as to the statements being made herein.
That Defendant, ANDRE ST. STEVE KIFFIN, is not in the military service of the United
States of America.
Affiant's knowledge is based upon information provided by the United States Department of
Defense Manpower Data Center or by the inquiry conducted by the Plaintiffs process server.
VERIFICATION
Under the penalties of perjury, I declare that I have read the foregoing Affidavit as to
Non-Military Status, and the facts stated in it are true on this 3 day of December, 2019.
\S\Lindsay Yarmuth
Lindsay Yarmuth, Esq.
Fla. Bar Number: 93156
19-376234 - MaT
PAGE 1
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/04/2019 11:40:18 AM.*###*
Department of Defense Manpower Data Center Results ag of. Oee-03-2019.01:17.09 PM
SCRA 5.2
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN:
Birth Date: a
Last Name: KIFFIN
First Name: ANDRE
Middle Name: ST STEVE
Status As Of: Dec-03-2019
Certificate ID: B389ZXT6HH53GHY
‘On Active Duly On Active Duty Status Date
Active: Duty Start Oste Active Outy End Date Status ‘Service Component
NA NA No NA
Ties resporse reflecis the widiiduals' acbve duly slafus based on the Active Duty Status Date
Left Actnve Duty Within 287 Days of Activa Duly Status Date
Active Duty Sian Date Active Duly End Date ‘Status Service Component
Na MA we NA
This respretse refiscis where the: individual [oft active chity status wehin 367 days preceding tne Active Duly Status Dale
‘Tha Memberor Histfer Unit Waa Notified of @ Future Call-Up to Active Duty on Active Dury Status Date
‘Order Notfcatan Start Date ‘Order Notiécabon Fd Date ‘Stats ‘Service Component
wa HA No NA
This response reflects wnether the indradual or his/her unit hes recelved early nottication to reportfor active Guty
Upon searching the data banks of the Department of Defense Manpower Data Center. based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Cons. Alt Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Michael ¥. Sorrento. Director
Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
‘The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) thal maintains the Defense Enrollment and Eligibitity
Reporting System (DEERS} database which is the official source of dala on eligibility for multary medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. ? 601 et seq, as amended) (SCRA) (formerly known as
the Soichers' and Sailors’ Civil Rellef Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individuat is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly ancouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (033) via this URL: https://scra.dmdc.osd.mil/faq.xhtmi#Q33. If you have evidence the person
was on active duly for the active duty status date and you fail to obtain this addittonal Service venification. punitive provisions of the SCRA may be invoked
agalast you. Sea 50 USC App. ? 621(c).
This response reflects the following information” (1) The individual's Actve Duty status on the Active Duty Status Date (2) Whether the individual teft Active
Duty status within 367 days preceding tha Active Duty Status Date (3) Whather the Individual o¢ his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on “Active Duty Status"
Active duly status as reported In this certificate is defined in accordance with 10 USC ? 101{d) (4}. Prior ta 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the Nationat Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC 7 502(f} for purposes of responding to a national emergency declared by the
Presidant and supparted by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization pasition in the
unit they support. This includes Navy Training and Administration of the Reserves {TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs), Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Aimospheric Administration (NOAA Commissioned Corps}.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duly records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC ? 101(d}{1).
Many times orders are amended to extend the parled of activa duty. which would exland SCRA protections. Persons seeking to raly on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inctusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty o¢ actually reparted for induction. The Last Date an Active Duty entry Is Important because a number of protections af the SCRA
extend beyond the last dates of active duty.
‘Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights quarantaed to Service members under tha SCRA
are protected
WARNING. This certificate was provided based on a last name. SSNidate of birth, and active duty status date provided by tha raquestar. Providing
erroneous information will cause an emoneous Certificate to be provided.
Department of Defense Manpower Data Center Results ag of. Oee-03-2019.01:17.83 PM
SCRA 5.2
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN:
Birth Date:
a
Last Name: KIFFIN
First Name: ANDRE
Middle Name:
Status As Of: Dec-03-2019
Certificate ID: BSY1KZX3RFMGMFK
‘On Active Duly On Active Duty Status Date
Active: Duty Start Oste Active Outy End Date Status ‘Service Component
WA NA No NA
Ties resporse reflecis the widiiduals' acbve duly slafus based on the Active Duty Status Date
Left Actnve Duty Within 287 Days of Activa Duly Status Date
Active Duty Sian Date Active Duly End Date ‘Status Service Component
Na MA we NA
This respretse refiscis where the: individual [oft active chity status wehin 367 days preceding tne Active Duly Status Dale
‘Tha Memberor Histfer Unit Waa Notified of @ Future Call-Up to Active Duty on Active Dury Status Date
‘Order Notfcatan Start Date ‘Order Notiécabon Fd Date ‘Stats ‘Service Component
wa HA No NA
This response reflects wnether the indradual or his/her unit hes recelved early nottication to reportfor active Guty
Upon searching the data banks of the Department of Defense Manpower Data Center. based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Cons. Alt Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Michael ¥. Sorrento. Director
Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
‘The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) thal maintains the Defense Enrollment and Eligibitity
Reporting System (DEERS} database which is the official source of dala on eligibility for multary medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. ? 601 et seq, as amended) (SCRA) (formerly known as
the Soichers' and Sailors’ Civil Rellef Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individuat is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly ancouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (033) via this URL: https://scra.dmdc.osd.mil/faq.xhtmi#Q33. If you have evidence the person
was on active duly for the active duty status date and you fail to obtain this addittonal Service venification. punitive provisions of the SCRA may be invoked
agalast you. Sea 50 USC App. ? 621(c).
This response reflects the following information” (1) The individual's Actve Duty status on the Active Duty Status Date (2) Whether the individual teft Active
Duty status within 367 days preceding tha Active Duty Status Date (3) Whather the Individual o¢ his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on “Active Duty Status"
Active duly status as reported In this certificate is defined in accordance with 10 USC ? 101{d) (4}. Prior ta 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the Nationat Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC 7 502(f} for purposes of responding to a national emergency declared by the
Presidant and supparted by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization pasition in the
unit they support. This includes Navy Training and Administration of the Reserves {TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs), Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Aimospheric Administration (NOAA Commissioned Corps}.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duly records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC ? 101(d}{1).
Many times orders are amended to extend the parled of activa duty. which would exland SCRA protections. Persons seeking to raly on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inctusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty o¢ actually reparted for induction. The Last Date an Active Duty entry Is Important because a number of protections af the SCRA
extend beyond the last dates of active duty.
‘Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights quarantaed to Service members under tha SCRA
are protected
WARNING. This certificate was provided based on a last name. SSNidate of birth, and active duty status date provided by tha raquestar. Providing
erroneous information will cause an emoneous Certificate to be provided.
Department of Defense Manpower Data Center Results ag of. Oee-03-2019.01:19.39 PM
SCRA 5.2
Status Report
Pursuant to Servicemembers Civil Relief Act
SSN:
Birth Date:
a
Last Name: ST STEVE KIFFIN
First Name: ANDRE
Middle Name:
Status As Of: Dec-03-2019
Certificate ID: POMDNMSSCON7G8W
‘On Active Duly On Active Duty Status Date
Active: Duty Start Oste Active Outy End Date Status ‘Service Component
NA NA No NA
Ties resporse reflecis the widiiduals' acbve duly slafus based on the Active Duty Status Date
Left Actnve Duty Within 287 Days of Activa Duly Status Date
Active Duty Sian Date Active Duly End Date ‘Status Service Component
Na MA we NA
This respretse refiscis where the: individual [oft active chity status wehin 367 days preceding tne Active Duly Status Dale
‘Tha Memberor Histfer Unit Waa Notified of @ Future Call-Up to Active Duty on Active Dury Status Date
‘Order Notfcatan Start Date ‘Order Notiécabon Fd Date ‘Stats ‘Service Component
wa HA No NA
This response reflects wnether the indradual or his/her unit hes recelved early nottication to reportfor active Guty
Upon searching the data banks of the Department of Defense Manpower Data Center. based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Cons. Alt Force, NOAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
Michael ¥. Sorrento. Director
Department of Defense - Manpower Data Center
400 Gigling Rd.
Seaside, CA 93955
‘The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) thal maintains the Defense Enrollment and Eligibitity
Reporting System (DEERS} database which is the official source of dala on eligibility for multary medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. ? 601 et seq, as amended) (SCRA) (formerly known as
the Soichers' and Sailors’ Civil Rellef Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individuat is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family
member, friend. or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the
protections of the SCRA, you are strongly ancouraged to obtain further verification of the person's status by contacting that person's Service. Service contact
information can be found on the SCRA website's FAQ page (033) via this URL: https://scra.dmdc.osd.mil/faq.xhtmi#Q33. If you have evidence the person
was on active duly for the active duty status date and you fail to obtain this addittonal Service venification. punitive provisions of the SCRA may be invoked
agalast you. Sea 50 USC App. ? 621(c).
This response reflects the following information” (1) The individual's Actve Duty status on the Active Duty Status Date (2) Whether the individual teft Active
Duty status within 367 days preceding tha Active Duty Status Date (3) Whather the Individual o¢ his/her unit received early notification to report for active
duty on the Active Duty Status Date.
More information on “Active Duty Status"
Active duly status as reported In this certificate is defined in accordance with 10 USC ? 101{d) (4}. Prior ta 2010 only some of the active duty periods less
than 30 consecutive days in length were available. In the case of a member of the Nationat Guard, this includes service under a call to active service
authorized by the President or the Secretary of Defense under 32 USC 7 502(f} for purposes of responding to a national emergency declared by the
Presidant and supparted by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization pasition in the
unit they support. This includes Navy Training and Administration of the Reserves {TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve
Program Administrator (RPAs), Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S.
Public Health Service or the National Oceanic and Aimospheric Administration (NOAA Commissioned Corps}.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duly records for all the Uniformed Services periods.
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC ? 101(d}{1).
Many times orders are amended to extend the parled of activa duty. which would exland SCRA protections. Persons seeking to raly on this website
certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inctusive dates of service.
Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not
actually begun active duty o¢ actually reparted for induction. The Last Date an Active Duty entry Is Important because a number of protections af the SCRA
extend beyond the last dates of active duty.
‘Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights quarantaed to Service members under tha SCRA
are protected
WARNING. This certificate was provided based on a last name. SSNidate of birth, and active duty status date provided by tha raquestar. Providing
erroneous information will cause an emoneous Certificate to be provided.