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Witness Exhibit List – Defendant
IN THE CIRCUIT COURT OF THE
11TH JUDICIAL CIRCUIT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA
WELLS FARGO BANK, N.A.
CASE NO: 09-00xxxx-CA-(13)
A.M and M.A., et. al.
DEFENDANTS, A.M and M.A.’S, WITNESS AND EXHIBIT LIST
Defendants, A.M and M.A., file this Witness and Exhibit List pursuant to Foreclosure Uniform Order Setting Cause for Non-Jury Trial, and Trial Instructions dated August 3, 2012, as follows:
I. WITNESS LIST
1. A.M. c/o The Law Office of Sackrin & Tolchinsky, P.A.
2. M.M c/o The Law Office of Sackrin & Tolchinsky, P.A.
3. A.M, Georgia
4. A.M., Georgia
II. EXHIBIT LIST
1. Judicial notice of the public records of Miami-Dade County pertaining to the subject property, 3403 Southwest 152nd Pass, Miami, Florida 33185
2. Non-Identity Affidavit of A.M.
3. Non-Identity Affidavit of M.A.
4. Quit Claim Deed from A.M. and A.M. to A.M. and M.J.A. dated June 18, 2004.
5. Corrective Quit Claim Deed for the subject property dated June 11, 2009.
6. Letter from Wells Fargo to A.M. dated March 6, 2012.
7. Checks evidencing payment of Defendants pursuant to the loan modification
8. Abstract dated October 7, 2011 from L & V Abstract and Title Services on the subject property.
9. Statements from Wells Fargo acknowledging receipt of the modified loan amount.
10. Fax cover letter from M.A. to Ms. K.M. re: Modification for Loan # 0201867702.
CERTIFICATE OF SERVICE
IT IS HEREBY CERTIFIED that on September 18, 2012, a true and correct copy of the foregoing was Fax: 813.251.1541; E-Mail: firstname.lastname@example.org to: Julie Anthousis, Esq., and Ron Pereira, Esq., Ronald R. Wolfe & Associates, P.L , Esq., 4919 Memorial Hwy, Ste 200, Tampa, Florida 33634-7500.
SACKRIN & TOLCHINSKY, P.A.
Attorney for Defendant(s)
2100 East Hallandale Beach Blvd./Suite 200
Hallandale Beach, FL 33009
Telephone: (954) 458-8655
Facsimile: (954) 455-9649
ALAN D. SACKRIN, ESQ. Florida Bar No. 349070
LARRY TOLCHINSKY, ESQ. Florida Bar No 021997
This is a sample document related to a specific set of facts and circumstances and should not be used or relied upon if any foreclosure, deficiency judgment, short sale or any other real estate matter. We recommend and urge you to consult with an experienced lawyer for professional advice as each case is unique.