lee county mortgage foreclosure fraud

8/7/2019 Lee County Mortgage Foreclosure Fraud

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR LEE COUNTY, FLORIDACIVIL ACTIONUSBANKNATIONAL ASSOCIATION, ASTRUSTEE FOR GSMPS 2004-4,Plaintiff,

vs.CASE NO.: 36-2008-CA-055974DMSION:G

LARRY R. BRADSHAW, et ai,Defendant(s).- - - - - - - - - - - - - - - - - - - - - - - - ~ /

MOTION TO COMPELPlaintiff, US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR GSMPS 2004-4, by and through

its undersigned counsel, files this Motion to Compel production of documents, answers to Interrogatories andanswers to Request for Admissions and as grounds therefore states as follows:

1. The Plaintiff propounded Interrogatories, Request for Production and Request for Admissions onor about August 17,2009. Defendant had until September 22,2009, within which to respond to the above-referenced discovery.

2. Plaintiff contacted counsel for the Defendant to make a good faith effort to obtain the requestedoutstanding discovery responses and to date, Plaintiff has not received the requested responses from the Defendant.WHEREFORE, the Plaintiff respectfully requests this Court enter an Order Compelling the Production ofDocuments, answers to Interrogatories and answers to Request for Admissions referenced above as well as awardPlaintiff reasonable attorney's fees and costs as a result of this motion.

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail on this--1- day of October, 2009, to all parties on the attached service list.Florida Default Law Group, P.L.P.O. Box 25018Tampa, Florida 33622-5018(813) 251-4766

FILE_NUMBER: F08086375 DOC_ID: M025016

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>. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR LEE COUNTY, FLORIDA

CIVIL ACTIONUS BANK NATIONAL ASSOCIATION, AS TRUSTEEFOR GSMPS 2004-4,

Plaintiff,vs. CASE NO.: 36-2008-CA-055974DIVISION: GLARRY R. BRADSHAW, et aI,

Defendant(s).--------------------~/ NOTICE OF HEARINGTO: All parties on the attached Service List

PLEASE TAKE NOTICE that the Motion to Compel will be called up for hearing before The HonorableMICHAEL T. MCHUGH, Judge of the above-styled Court in Chambers in the LEE County Courthouse at 1700Monroe St. Court Room 16, 4th floor, Fort Myers, FL 33901, on February 22,2010 at 11:OOAMEST, or as soonthereafter as counsel may be heard.

PLEASE BE GOVERNED ACCORDfNGL Y. TIME RESERVED: FNE MINUTES.Please be advised that the defendant is pro-se, therefore, this hearing did not require coordination. Please be

advised that Plaintiffs counsel attempted to coordinate the above hearing with Opposing Counsel's office and wasunsuccessful after three (3) attempts, therefore, this hearing was scheduled unilaterally.

I HEREBY CERTIFY that a true and ' 4 O P Y of the foregoing has been furnished by U.S. Mail to allparties listed on the attached service list on this day of January, 2010.

FILE_NUMBER: F08086375 DOC_ID: M025011

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cc: Judge's Judicial Assistant**See Americans with Disabilities Act**

If you are a person with a disability who needs any accommodation in order to participate in thisproceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Ken Kellum,Court Operations Manager whose office is located at Lee County Justice Center, 1700 Monroe Street, FortMyers, Florida 33901, and whose telephone number is (239) 533-1700; within two working days of your receiptof this notice of sale; if you are hearing or voice impared, call1-SOO-955-S771 (TDD).


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2/22/2010 4:23 PM Filed Lee County Clerk of CourtIN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND fORLEE COUNTY, FLORIDA . CIVIL ACTION

US Bank National Association, atf GSMPSPlaintiff

vsBradshaw, Larry R etal

Defendant- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ / Case No.: OB-CA-055974

MINUTESDate: 2/22/10 Deputy Clerk: SylvesterJudge: George Richards Court Reporter:

Attorney for Defendant: Larry R Bradshaw~ Present 0Not Presento Present I Z I Not Present

Attorney for Plaintiff: Greg Goetz

Hearing Information, C 8 J Motion to Compel o Granted ~ Denied o Reserved

o Motion o Granted o Denied o Reservedo Motion o Granted o Denied o Reservedo Other: o Granted o Denied o ReservedNotes:

Order to be prepared by:~ Plaintiff's Attorney o Defendant's Attorney o Order signed in open court

o HEARING CANCELLED


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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUITIN AND FOR LEE COUNTY, FLORIDA

CIVIL ACTIONUS BANK NATIONAL ASSOCIATION, ASTRUSTEE FOR GSMPS 2004-4,

Plaintiff,vs.

CASE NO.: 36-2008-CA-055974DIVISION: G

LARRY R. BRADSHAW, et aI,Defendant(s)._______ ___________________ 1

CORRECTED ORDER ON PLAINTIFF'S MOTION TO COMPELTHIS CAUSE having come before the Court on February 22, 2010, on Plaintiffs Motion to Compel

and having reviewed the aforementioned documents and having heard the arguments of Plaintiffs Counsel and theDefendant, and being otherwise fully advised in the premises, it is

ORDERED AND ADJUDGED as follows:1. FPlaintiffs Motion to Compel is hereby GRANTED.2. Defendant has twenty (20) days to respond to discovery.

DONE AND ORDERED day of________ , 2010.

~~f~ll~'~b ~ C . -r~onformed copies to:Frances E. Johnson, Esquire

Florida Default Law Group, P.L.P.O. Box 25018Tampa, Florida 33622-5018All parties on the attached Service List

Circuit Court Judge

FILE_NUMBER: F08086375 DOCJD: M012913

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IN T H E C IR C U IT C O U R T O F T H E T W EN T IE T H JU D IC IA L C IR C U IT IN A N D F O RL EE C O U N T Y , FL O R ID A C IV IL A C T IO N

US Bank National Association, atf GSMPSPlaintiff

vsBradshaw, Larry R etalDefendant

,

________________________________ 1Case No.: OB-CA-055974

MINUTESDate: 2122110 Deputy Clerk: SylvesterJudge: George Richards Court Reporter:Attorney for Plaintiff. Greg Goetz I2 J Present

o Presento Not Present

Attorney for Defendant: Larry R Bradshaw I2 J Not Present

Hearing InformationI2 J Motion to Compel I2 J Granted o Denied o Reservedo Motion o Granted o Denied o Reservedo Motion o Granted o Denied o Reservedo Other: __ o Granted o Denied o ReservedNotes:

Order to be prepared by:I2 J Plaintiff's Attorney o Defendant's Attorney o Order signed in open court

o HEAR ING CANCELLED EILEDF E B 2 2 2 0 1 0..0 IA R1.l E G R EE N, C lE RK

C lR C U IT IC O lJ N T Y C O U R T SBY D.C