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Filing # 89168837 E-Filed 05/08/2019 11:39:01 AM
IN THE CIRCUIT COURT OF THE NINTH
JUDICIAL CIRCUIT IN AND FOR ORANGE
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO. 2017-CA-008145-O
US BANK NATIONAL ASSOCIATION, AS
SUCCESSOR TRUSTEE, TO BANK OF
AMERICA, NATIONAL ASSOCIATION,
SUCCESSOR BY MERGER TO LASALLE
NATIONAL ASSOCIATION, AS TRUSTEE FOR
OWNIT MORTGAGE LOAN TRUST,
MORTGAGE LOAN ASSET-BACKED
CERTIFICATES, SERIES 2006-7,
Plaintiff,
vs.
WANDA AGOSTO A/K/A WANDA AGOSTO
RODRIGUEZ AND RAFAEL AGOSTO A/K/A
RAFAEL O. AGOSTO, et al.
Defendant(s).
________________________________________/
PLAINTIFF'S TRIAL WITNESS AND EXHIBIT LIST
COMES NOW the Plaintiff, US BANK NATIONAL ASSOCIATION, AS SUCCESSOR
TRUSTEE, TO BANK OF AMERICA, NATIONAL ASSOCIATION, SUCCESSOR BY
MERGER TO LASALLE NATIONAL ASSOCIATION, AS TRUSTEE FOR OWNIT
MORTGAGE LOAN TRUST, MORTGAGE LOAN ASSET-BACKED CERTIFICATES,
SERIES 2006-7, by and through its undersigned counsel, and files this Witness and Exhibit List
for Trial, and states as follows:
WITNESS LIST
1. Representative of Plaintiff will 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.
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2. Other representatives on behalf of Plaintiff competent to testify in this matter.
3. Anna Garza, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
4. Ben Verdooren, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
5. Blaine Shadle, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
6. Carlos Steele, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
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7. Cedric Bankston, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
8. Derrick Raleigh, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
9. Richard Schwiner, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
10. Russell Calhoun, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
11. Sally Torres, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will testify as to the business records of the Plaintiff
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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.
12. Sheila King, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
13. Fred Denson, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
14. Louise Plasse, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
15. Joachim (Jay) Vent, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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
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bring the subject action and as to the origination, processing, and servicing of Defendant’s
loan and Plaintiff’s business records.
16. Richard Pierre, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
17. Sandra Tramble, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
18. Sherry Keeley, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
19. Kay McDowell, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin, Esq.,
6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
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20. Anel Hernandez, Senior Loan Analyst, Ocwen Loan Servicing, LLC, c/o Hillary Mullin,
Esq., 6409 Congress Ave., Suite 100, Boca Raton, FL 33487, Telephone: 561-241-6901, Fax:
561-997-6909 Representative of Plaintiff will 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.
21. All witnesses listed by the Defendant(s).
22. The remaining Defendant(s).
23. Plaintiff’s Attorney fee expert.
24. Plaintiff’s attorney may testify as to the fees and costs incurred in this matter.
25. Rebuttal and impeachment witnesses.
26. Any person(s) listed on the Note, Mortgage, and Assignment of Mortgage.
27. 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
know or necessary, upon property notice to the other parties.
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EXHIBIT LIST
1. Bailee Letter
2. Document Tracker
3. Hello/Goodbye Letter
4. Power of Attorney
5. Public Records
6. Pooling and Servicing Agreement with Mortgage Loan Schedules
7. Subject Note with endorsements and/or allonges.
8. Subject Mortgage.
9. All Assignments of Mortgage relating to the subject Note and Mortgage.
10. Copies of all Notices of Default and Intent to Accelerate/Foreclose letters sent to borrower(s).
11. 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.
12. All time records and billing statements for the fees and costs incurred by plaintiff.
13. All Affidavits of Time, Effort and Costs, Affidavits as to Reasonableness of Attorneys’ Fees,
and/or Affidavits of Indebtedness.
14. Any and all correspondence between the parties.
15. All loan servicing and collection notes.
16. All exhibits listed by Defendant.
17. All pleadings and attachments/exhibits thereto and all documents contained in court file for
subject action.
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18. All discovery and attachments/exhibits thereto.
19. All impeachment and rebuttal exhibits.
20. HUD-1 Settlement Statement
21. Title Policies
22. Title Commitments
23. Loan Application
24. Loan Origination Documents
25. HOA/COA Declaration of Covenants
26. Deed(s)
27. 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.
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was emailed and/or
mailed on this 8 day of May, 2019, to the attached service list.
ROBERTSON, ANSCHUTZ & SCHNEID, P.L.
Attorney for Plaintiff
6409 Congress Ave., Suite 100
Boca Raton, FL 33487
Telephone: 561-241-6901
Facsimile: 561-997-6909
Service Email: mail@rasflaw.com
By: _\S\Laurence S. Barsky_
Laurence S. Barsky, Esquire
Florida Bar No. 515981
Communication Email: lbarsky@rasflaw.com
SERVICE LIST
MARTIN LAW GROUP, P.L.
ANTONIO G. MARTIN
ATTORNEY FOR WANDA AGOSTO A/K/A WANDA AGOSTO RODRIGUEZ A/K/A
WANDA I. AGOSTA A/K/A WANDA I. RODRIGUEZ
C/O MARTIN LAW GROUP, P.L.
1420 CELEBRATION BLVD SUITE 200
CELEBRATION, FL 34747
PRIMARY EMAIL: INFO@CALLMARTINLAWGROUP.COM
RAFAEL AGOSTO A/K/A RAFAEL O. AGOSTO
3200 OLD WINTER GARDEN RD APT 2024
OCOEE, FL 34761
BLANK ROME, LLP
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DANIEL S. HURTES
ATTORNEY FOR MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR OWNIT MORTGAGE SOLUTIONS, INC.
C/O BLANK ROME, LLP
500 E. BROWARD BLVD., SUITE 2100
FT LAUDERDALE, FL 33394
PRIMARY EMAIL: DHURTES@BLANKROME.COM
SECONDARY EMAIL: BRFLESERVICE@BLANKROME.COM
ORANGE COUNTY ATTORNEY'S OFFICE
CRISTINA T. BERRIOS, ESQ.
ATTORNEY FOR ORANGE COUNTY, FL
C/O ORANGE COUNTY ATTORNEY'S OFFICE
201 S. ROSALIND AVE, 3RD FLOOR
ORLANDO, FL 32802
PRIMARY EMAIL: FORECLOSURE.ESERVE@OCFL.NET
ISPC
MICHAEL D. GINSBERG
ATTORNEY FOR THE INDEPENDENT SAVINGS PLAN COMPANY DBA ISPC
C/O ISPC
1115 GUNN HIGHWAY SUITE 100
ODESSA, FL 33556
PRIMARY EMAIL: FC-ISPC@THEISPC.COM
SECONDARY EMAIL: MDGLAW@THEISPC.COM
BLANK ROME, LLP
DANIEL S. HURTES
ATTORNEY FOR U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE
CBASS MORTGAGE LOAN ASSET-BACKED CERTIFICATES, SERIES 2007-SL1
C/O BLANK ROME, LLP
500 E. BROWARD BLVD., SUITE 2100
FT LAUDERDALE, FL 33394
PRIMARY EMAIL: DHURTES@BLANKROME.COM
SECONDARY EMAIL: BRFLESERVICE@BLANKROME.COM
MARTIN LAW GROUP, P.L.
ANTONIO G. MARTIN
ATTORNEY FOR ANTONIO G. MARTIN, ESQ, AS TRUSTEE OF THE DERRICK DRIVE
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LAND TRUST #6826 DATED AUGUST 1, 2017
C/O MARTIN LAW GROUP, P.L.
1420 CELEBRATION BLVD SUITE 200
CELEBRATION, FL 34747
PRIMARY EMAIL: INFO@CALLMARTINLAWGROUP.COM
MARTIN LAW GROUP, P.L.
ANTONIO G. MARTIN
ATTORNEY FOR UNKNOWN SUCCESSOR TRUSTEE OF THE DERRICK DRIVE LAND
TRUST #6826 DATED AUGUST 1, 2017
C/O MARTIN LAW GROUP, P.L.
1420 CELEBRATION BLVD SUITE 200
CELEBRATION, FL 34747
PRIMARY EMAIL: INFO@CALLMARTINLAWGROUP.COM
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