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BANK, Plaintiff, vs. JOHN CARROLL, et al Defendants ____________________________________________/ DEFENDANT JOHN CARROLL’S MEMORANDUM IN OPPOSITION TO PLAINTIFF HANCOCK’S MOTIONS FOR SUMMARY FINAL JUDGMENT AND ATTORNEY’S FEES AND COSTS Defendant John Carroll (“Carroll”), pursuant to Florida Rule of Civil Procedure 1.510(c) moves for an Order Denying Hancock Bank’s (“Hancock”) Motion for Summary Final Judgment for the following reasons and shows: 1. To Hancock’s Paragraph 1 of their Motion, Carroll confirms that Hancock Case No.: 09CA000607
has filed a Motion for Final Summary Judgment. 2. To Hancock’s Paragraph 2 of their Motion, Carroll confirms that Hancock
has filed this action under Florida’s foreclosure statutes, which must be perfected in accordance with applicable Florida case law and Florida Rules of Civil Procedure. 3. To Hancock’s Paragraph 3 of their Motion: a) Carroll (and the Court file) disputes this. Hancock is fully aware
that they have not served all parties to their complaint. b) Due service of process is essential to satisfy jurisdictional
requirements over the subject matter and the parties in a foreclosure action per Rule 1.070,
Fla. R. of Civ. P. (2011) and Chapters 48 and 49 of the Florida Statutes. c) Service of process must be made upon the defendant within 120
days after the filing of the initial pleading. Rule 1.070(j), Fla. R. Civ. P. (2011). Absent a showing of excusable neglect or good cause, the failure to comply with the time limitations may result in the court’s dismissal of the action without prejudice or the dropping of the defendant. d) On June 2, 2010, Hancock Moved for an Extension of Time to
Effectuate Service. On June 7, 2010 this Court Granted Hancock’s Motion and gave Hancock an additional 180 days to perfect service. Hancock’s extension of time to
effectuate service expired 461 days ago. As such, Carroll Moves for Dismissal. e) Without proof of service demonstrating adherence to due process
requirements, the Plaintiff is not entitled to entry of a final judgment. Failure to effectuate service - places the jurisdiction in a state of dormancy during which the trial court or clerk is without authority to enter a final judgment. Armet S.N.C. di Ferronato Giovanni & Co. v. Hornsby, (Fla. 1st DCA 1999); Tetley v. Lett, (Fla. 4th DCA 1984). f) Statutes governing service of process are strictly construed. General
de Seguros, S.A. v. Consol. Prop. & Cas. Ins. Co., (Fla. 3rd DCA 2001) (reversed with directions to vacate judgment and quash service of process since substituted service was not perfected). g) All Judgments are subject to collateral attack where plaintiff did not
substantially comply with the statutory requirements of service. 4. On October 18, 2011, Carroll filed and served his Answer to Hancock’s
Complaint. Carroll’s Answer contained the following Affirmative Defenses:
I. II. III.
Fraud in the Inducement Failure of Consideration Deceptive and Unfair Trade Practices and Breach of Implied
Covenant of Good Faith and Fair Dealing IV. V. VI. VII. VIII. IX. X. XI. XII. 5. Moral and Economic Duress Promissory Estoppel Equitable Estoppel Laches Unclean Hands Waiver Anticipatory Repudiation Setoff Unconscionability
Hancock did not file a Reply to Carroll’s affirmative defenses. The 1972
Amendment to Rule 1.100 Subdivision (a) was amended to make a reply mandatory when a party seeks to avoid an affirmative defense in an answer or third-party answer. 6.
Accordingly, plaintiff's failure to file a reply to the affirmative defenses had the effect of denying the allegations of the defenses. By having failed to reply to the defenses, plaintiff is not entitled to raise new matters in avoidance thereof. North American Philips Corp. v. Boles, 405 So.2d 202 (Fla. 4th DCA 1981). Thus, the fact issues related to Carroll’s (12) affirmative defenses must be tried prior to final judgment. 7. To Hancock’s Paragraph 4:
a) discovery continues. b)
Carroll disputes this, but has no specific response because
Carroll alleges that there is a written agreement or
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 8. To Hancock’s Paragraph 5: a) discovery continues. b) Carroll alleges that there is a written agreement or Carroll disputes this, but has no specific response because
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 9. To Hancock’s Paragraph 6: a) discovery continues. b) Carroll alleges that there is a written agreement or Carroll disputes this, but has no specific response because
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 10. To Hancock’s Paragraph 7: a) discovery continues.
Carroll disputes this, but has no specific response because
Carroll alleges that there is a written agreement or
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 11. To Hancock’s Paragraph 8: a) discovery continues. b) Carroll alleges that there is a written agreement or Carroll disputes this, but has no specific response because
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 12. To Hancock’s Paragraph 9: a) discovery continues. b) Carroll alleges that there is a written agreement or Carroll disputes this, but has no specific response because
representation which supports Carroll’s defenses. Discovery is not complete in this case but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. 13. To Hancock’s Paragraph 10: a) discovery continues. b) Carroll alleges that there is a written agreement or Carroll disputes this, but has no specific response because
representation which supports Carroll’s defenses. Discovery is not complete in this case
but already the record shows that John Carroll’s firm Chambers Street Builders, Inc. deposited $111,550.71 for the loan and Peoples First received the benefit of said deposit. Standard of Review 14. Under Florida Law, summary judgment is proper if, and only if, based upon
examination of evidence, no genuine issue of material fact exists and the movant is entitled to judgment as a matter of law The Florida Bar v. Green, (Fla. 2006); Volusia County v. Aberdeen at Ormond Beach, L.P., (Fla. 2000). 15. Furthermore, pursuant to Rule 1.510, a Court may grant summary judgment
if, and only if, “the pleadings, depositions, answers to interrogatories, and admissions on file together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law.” 16. Finally, the Court must take all the facts that the non-movant states as true
and must draw all reasonable inferences in favor of the non-moving party Bradford v. Bernstein, (Fla. 2nd DCA 1987); Petruska v. Smartparks-Silver Springs, Inc., (Fla. 5th DCA 2005). Argument and Citations in Support of Defendant’s Opposition I. Hancock’s Motion Should Be Denied Because of Outstanding Discovery It is a long standing rule that a decision regarding summary judgment will
not be entered where there is outstanding discovery. In Henderson v. Reyes, (Fla. 3rd DCA 1997), the 3DCA held that it was an error for the trial court to enter a final summary judgment of foreclosure while there were depositions that had not been completed and an outstanding request for production of documents.
See also Villages at Mango Key
Homeowners Ass’n, Inc. v. Hunter Development, Inc., (Fla. 5th DCA 1997) (holding that summary judgment is inappropriate and premature when discovery is ongoing and depositions or other discovery are outstanding); Collazo v. Hupert, (Fla. 3d DCA 1997) (holding that while “discovery was still pending, the trial court should not have entertained a motion for summary judgment until such discovery was concluded.”) 18. Here, Hancock has not served the lead Defendant, J.M.B., L.L.C., with the
complaint. Hancock has conducted no discovery, and has failed to truly commence the litigation. 19. On the other hand, Carroll has been seeking the complete loan file from
Hancock’s predecessor, People’s First Community Bank, since the inception of the litigation (as first found in the Court Record (2) years prior to the filing of their Motion for Summary Judgment.) Further, at this time the first round of depositions has not been scheduled and there is an outstanding request for production of the Plaintiff. Wherefore, because there is outstanding discovery in this case, Carroll respectfully requests this Court deny Plaintiff’s Motion for Summary Judgment, and any other relief the Court deems just and proper. II. Hancock’s Motion Should Be Denied Because Hancock Failed to Reply to Carroll’s Affirmative Defenses Florida Courts disallow summary judgment when plaintiffs fail to refute
affirmative defenses. In Lazuran v. Citimortgage, Inc., (Fla. 4th DCA 2010), the Court held the trial court’s grant of summary judgment improper where the plaintiff failed to refute an affirmative defense. Carroll’s Answer and Affirmative Defenses set forth genuine existence of material facts which precludes entry of summary judgment. Manassas Investments Inc.
v. O’Hanrahan, (Fla. 2nd DCA 2002). See also, Frost v. Regions Bank, (Fla. 4th DCA 2009) (Because the bank did not meet its burden to refute the Frosts’ lack of notice and opportunity to cure defense, the bank is not entitled to final summary judgment of foreclosure.). 21. Here, Carroll has pleaded (12) legally sufficient defenses to Hancock’s
claims, and Hancock has not attempted to defeat them. “Affirmative defenses do not simply deny the facts of the opposing party’s claim; they raise some new matter which defeats an otherwise apparently valid claim.” Wiggins v. Protmay, (Fla. 1st DCA 1983). Hancock must either factually refute Carroll’s affirmative defenses or establish that they are legally insufficient. Frost v. Regions Bank, (Fla. 4th DCA 2009). 22. To perfect the Record on any appeal, Carroll recites and reincorporates said
affirmative defenses exactly as they appear in his Answer to Hancock’s complaint: ________________________________________________________________________ AFFIRMATIVE DEFENSES Statements of fact common to all Carroll’s Defenses and Claims 28. Original Plaintiff, Peoples First Community Bank (“PEOPLES”), entered
into the contracts attached to Peoples Complaint with Carroll and J.M.B., L.L.C. simultaneously with additional contracts. 29. Hancock has failed to attach those additional agreements to its Complaint.
Those additional agreements modified the terms of the agreements sued upon. 30. Carroll has made 3 pre-suit qualified written requests of Peoples, pursuant
to 12 U.S.C. §2605(e). The last of which was served upon Peoples on March 10, 2009 to
provide information related to the servicing of the loan underlying this matter and the corresponding accounting of such loan (see attached Exhibit A). 31. January 2007, Peoples and their Senior Officer William “Tommy” Harrison,
informed Carroll that he was approved for a construction loan of $1,650,000.00 under the condition that Carroll participate in, and perform for 6 months in, the mortgage attached to Hancock’s Complaint. 32. Carroll and his companies performed according to the terms of their
agreement, but Peoples and William “Tommy” Harrison (“TOMMY”) did not perform. I. FRAUD IN THE INDUCEMENT 33. restated here. 34. Tommy and Peoples made numerous false statements of material fact Carroll incorporates by reference paragraphs 28 through 32 as if fully
regarding their intention to advance Carroll and his companies’ additional financing. 35. false. Tommy and Peoples knew or should have known their representations were
Only they understood how they had obtained authority to give financing
commitments. Providing financing commitments is routine business for professionals in their position. 36. Tommy and Peoples gave Carroll financing commitments in order to induce
Carroll and Chambers Street Builders, Inc. to deposit $100,000.00 with Peoples. 37. Carroll and his business interests have suffered economic damage by not
being able to forecast an avoidable catastrophic loss. Carroll would never have endorsed the Mortgage at issue here. Carroll would never have approved the $100,000.00 advance to Peoples. Carroll would never have undertaken to commence construction on Lot 24
without financing. Carroll had done business with Tommy and Peoples for 5 years and their commitments were always given in the same way as the commitments alleged herein. Given all of the factors previously mentioned Carroll was justified to rely on Tommy and Peoples’ representations. II. FAILURE OF CONSIDERATION 38. restated here. 39. Carroll and Chambers Street Builders, Inc. provided the $100,000.00 cash Carroll incorporates by reference paragraphs 28 through 32 as if fully
to Peoples and performed under the contract as agreed. 40. financing. 41. Tommy and Peoples reneged on their commitment yet Peoples and Tommy Tommy and Peoples agreed to provide the additional $1,650,000.00
have given Carroll and his companies no consideration. 42. consideration. III. DECEPTIVE AND UNFAIR TRADE PRACTICES AND BREACH OF IMPLIED COVENANT OF GOOD FAITH AND FAIR DEALING 43. restated here. 44. Tommy and Peoples have engaged in unconscionable acts or practices, and Carroll incorporates by reference paragraphs 28 through 32 as if fully The Plaintiff’s cause of action is barred as a result of Coastal’s failure of
unfair or deceptive acts or practices as implied by Florida Law by luring Carroll and his businesses into agreements which they did not intend to honor.
These acts are the proximate cause of economic damages to Carroll and his
business interests. IV. MORAL AND ECONOMIC DURESS 46. restated here. 47. Carroll was forced to sign the March 10, 2008 extension on the underlying Carroll incorporates by reference paragraphs 28 through 32 as if fully
promissory note on terms that were aberrant because Carroll relied on Tommy and Peoples’ assertions that this was the only way to effectuate the impending $1,650,000.00 financing. 48. Carroll’s actions were involuntary and not an exercise of his free will,
because Carroll had committed in contract to advance $100,000.00 to Peoples and spent substantial economic reserves. 49. Carroll’s corresponding condition of mind was caused by Tommy and
Peoples’ improper and coercive conduct. V. PROMISSORY ESTOPPEL 50. restated here. 51. Tommy and Peoples misrepresented the fact that the $1,650,000.00 loan Carroll incorporates by reference paragraphs 28 through 32 as if fully
was pending and approved. 52. Tommy and Peoples expected to induce Carroll to advance $100,000.00
towards the contract. 53. Tommy and Peoples expected to induce Carroll to forbear the hoarding of
his and his companies’ cash.
Tommy and Peoples’ misrepresentations succeeded in inducing the actions
and forbearances by Carroll. 55. Carroll and his businesses suffered severe detriments by the reliance on the
misrepresentations. VI. EQUITABLE ESTOPPEL 56. restated here. 57. Tommy and Peoples represented that they are committed to closing the Carroll incorporates by reference paragraphs 28 through 32 as if fully
enhanced financing with Carroll. 58. this time. 59. 60. Carroll relied(s) on the representations. Carroll is suffering detriment by the change of position as a result of the This representation is contrary to the condition of current affairs asserted at
representations and his reliance thereon. VII. LACHES 61. restated here. 62. Tommy, Peoples and Senior VP, Bill Haddock, all were routinely apprised Carroll incorporates by reference paragraphs 28 through 32 as if fully
and physically inspected Carroll and his companies’ improvements over the 25 months preceding the initiation of this court action. 63. Each and every party named above condoned Carroll’s infusion of equity to
Peoples during the 25 months described as a trade off.
Plaintiff intentionally slept on its right to initiate this action in order to be
enriched by Carroll’s equity infusions and enhancements to the value of Lot 150. 65. Carroll and his business interests are severely prejudiced by Peoples’
belated initiation of this action. 66. Enforcement by Plaintiff at this late stage would be inequitable and unjust. VIII. UNCLEAN HANDS 67. restated here. 68. Tommy and Peoples’ actions in this matter are condemned by honest and Carroll incorporates by reference paragraphs 28 through 32 as if fully
reasonable persons. 69. Based on Carroll’s allegations against the Plaintiff, the default and
foreclosure would not have occurred but for the Plaintiff’s unclean hands. 70. Peoples seeks a remedy but its inequitable conduct, constituting unclean
hands, bars the granting of relief to Peoples requested herein. IX. WAIVER 71. restated here. 72. Carroll is informed and believes, and on such information and belief Carroll incorporates by reference paragraphs 28 through 32 as if fully
alleges, that Peoples engaged in conduct that constitutes a waiver of their rights under the agreements at issue as implied by Florida law. 73. By reason of said waiver, Carroll is excused from further performance of
the obligations under the alleged contract.
X. ANTICIPATORY REPUDIATION 74. restated here. 75. Carroll and Peoples had a contract with written memo’s whereby Peoples Carroll incorporates by reference paragraphs 28 through 32 as if fully
would advance Carroll an additional $1,650,000.00. 76. Tommy and Peoples instructed Carroll and his companies to advance
Peoples $100,000.00. Carroll advanced said funds. 77. contract. 78. Peoples continues to refuse to close the loan and pay Carroll and his Carroll satisfied his obligation to Peoples under the terms of the parties’
companies for their work under the agreement. The agreement provided that Carroll and his companies would be paid $1,350,000.00 for the present level of completion of the contract. 79. Tommy and Peoples’ affirmative actions have rendered performance of the
contract impossible or apparently impossible. 80. Peoples’ breach entitles Carroll to change his position under the contract,
wiping out Peoples’ claims in this action. X. SETOFF 81. restated here. 82. After the institution of the amended agreement Peoples falsely and Carroll incorporates by reference paragraphs 28 through 32 as if fully
fraudulently represented to Carroll that it had approved and intended to close the enhanced loan to Carroll.
In reliance on this representation and Tommy’s instructions to Carroll,
Carroll advanced Peoples $100,000.00. 84. Carroll has been economically damaged by Peoples’ breach of the
agreement and has a right to offset any money that may be owed to Peoples. XI. UNCONSCIONABILITY 85. restated here. 86. efforts. 87. Tommy and Peoples’ ambitions and attempts to acquire Carroll’s equity Carroll has advanced Peoples $100,000.00 as a result of his sacrifices and Carroll incorporates by reference paragraphs 28 through 32 as if fully
without paying the full value to Carroll are unconscionable. Their complaint should be barred. ________________________________________________________________________ 23. As mentioned above, summary judgment is only proper if no genuine issue
of material fact exists. Carroll has raised a number of genuine issues of material fact in his affirmative defenses. By failing to reply to these affirmative defenses, Hancock has failed to respond to genuine issues of material facts that Carroll has raised. Wherefore, because Hancock has failed to respond to Carroll’s affirmative defenses in this case, and because this Court has not ruled upon Carroll’s affirmative defenses, Carroll respectfully request this Court deny Hancock’s Motion for Summary Judgment, and any other relief the Court deems just and proper. III. the Hancock’s Motion for Summary Judgment Should be Denied and its Affidavit of Amounts Due and Owing Should be Struck because Affiant Failed to Attach Documents Referred to in the Affidavit.
Rule 1.510(e) provides, in part, that “[s]worn or certified copies of all
papers or parts thereof referred to in an affidavit shall be attached thereto or served therewith.” 25. Failure to attach such papers is grounds for reversal of summary judgment
decisions. In CSX Transp., Inc. v. Pasco County, (Fla. 2nd DCA 1995) the 2DCA reversed summary judgment granted below, in part, because the affiant based his statements on reports but failed to attach same to the affidavit. The 2DCA noted that because these statements were based upon said reports, they were consequently not based upon the affiant’s personal knowledge, and were therefore inadmissible hearsay statements. 26. It is also most important that an affiant state in detail the facts showing that See Hoyt v. St. Lucie County, Bd. of County
the affiant has personal knowledge.
Comm’rs, (Fla. 4th DCA 1998) (holding an affidavit legally insufficient where it failed to reflect facts demonstrating how the affiant would possess personal knowledge of the matters at issue in the case); Carter v. Cessna Fin. Corp., (Fla. 4th DCA 1986) (holding an affidavit legally insufficient where the affiant failed to set out a factual basis to support a claim of personal knowledge of matter at issue in the case and failed to make assertions based on personal knowledge). 27. The 3rd DCA, in Alvarez v. Florida Ins. Guaranty Association, (Fla. 3rd DCA
1995) noted that “the personal knowledge requirement is to prevent the trial court from relying on hearsay when ruling on a motion for summary judgment and to ensure that there is an admissible evidentiary basis for the case rather than mere supposition or belief.” (quoting Pawlik v. Barnett Bank of Columbia County, (Fla. 1st DCA 1988))
This opposition to hearsay evidence has deep roots in Florida. In Capello v.
Flea Market U.S.A., Inc., (Fla. 3rd DCA 1993), the 3DCA affirmed an order of summary judgment in favor of Flea Market U.S.A. as Capello’s affidavit in opposition was not based upon personal knowledge and therefore contained inadmissible hearsay evidence. See also Doss v. Steger & Steger, P.A., (Fla. 4th DCA 1993); Mullan v. Bishop of Diocese of Orlando, (Fla. 5th DCA 1989); Crosby v. Paxson Electric Company, (Fla. 1st DCA 1988); and Page v. Stanley, (Fla. 4th DCA 1969). 29. The affidavit offered by Hancock in support of its Motion for Summary
Judgment avers that “The Affiant has read the Complaint and knows from her own personal knowledge that the allegations and facts contained therein are true, accurate and correct” 30. First, it is patently obvious that the affiant, Michael Howell, is not a her
which makes it clear that the Affidavit used is a recycled, boilerplate affidavit, not a statement of fact specific to this case. 31. The Affiant claims the statements are based on her own personal knowledge
but never explains how he has knowledge of the statements in the loan service records, if he prepares the loan service records, or how he who identifies himself with Hancock Bank has any knowledge of the facts of the case pertaining Peoples First Community Bank. 32. In spite of the Affiant’s general contention that “The Affiant has read the
Complaint and knows from her own personal knowledge that the allegations and facts contained therein are true, accurate and correct” the Affiant once again failed to aver with any specificity or particularity how he has personal knowledge of the matters contained in
these books, records and documents of Peoples First which form the basis of his statements. 33. The affiant admits that he is in the “Special Assets Department of Hancock
Bank”. That may explain why his affidavit is in conflict with itself wherein he swears (on page 2 of the affidavit) that as of January 26, 2012, there is interest in the amount of $314,580.80 due, yet on the only documentation attached to the affidavit (Exhibit 2 of the affidavit) the total interest due as of January 26, 2012 is $144,462.08. 34. Therefore, it can only be concluded based upon the statements contained in
the affidavit that (1) the statements contained within the loan payment records were prepared by someone other than Michael Howell, such as an employee of Peoples First whose duty it was to keep the books accurately and completely; and (2) the affiant has absolutely no personal knowledge of the matters contained within the books, records and documents. 35. Since the affiant’s statements were in fact not based upon his personal
knowledge they are therefore hearsay. The only way to cure this fatal defect would be for the affiant to have attached the books, records and documents which formed the basis of the affiant’s statements. 36. Nevertheless, the affiant has failed to attach any of these books, records and
documents to the affidavit. Thus, the affiant’s statements remain inadmissible hearsay. 37. Hancock may argue that while the affiant’s statements may be hearsay, they
should nevertheless be admitted under “Records of Regularly Conducted Business Activity” exception at Fla. Stat. 90.803(6). That is, “unless the sources of information or other circumstances show lack of trustworthiness” part (a)
There are, however, several problems with this argument. To begin, no
memorandums, reports, records or data compilation have ever been turned over to Carroll or this Court by Hancock; thus the statements in question cannot be a memorandum, report, record or data compilation. 39. Moreover, the affiant shows a “lack of trustworthiness” because he averred
that his statements were based upon his “personal knowledge” when they were, in fact, not. 40. Finally, the 1DCA has recently held that lists of payments due and owing,
such as the list found at Exhibit 2 of the affidavit, are inadmissible hearsay statements and not business records; it is therefore an error to award summary judgment based upon such an affidavit. Mitchell Brothers, Inc. v. Westfield Ins. Co., (Fla 1st DCA 2009) 41. The failure of Hancock to attach the books, records, and documents referred
to in its affidavit is in direct violation of both the Florida Rules of Civil Procedure and multiple Florida State cases. Allowing the affidavit would lead to the admission of
inadmissible hearsay evidence and is grounds for a reversal of a summary judgment decision. Wherefore, because Hancock has failed to attach documents referred to in its affidavit, Carroll respectfully requests that this Court strike the Affidavit of Amounts Due and Owing, deny Hancock’s Motion for Summary Judgment, Dismiss Hancock’s Complaint for Failure to Effectuate Service upon J.M.B., L.L.C. and any other relief the Court deems just and proper.
I HEREBY CERTIFY that a copy of the foregoing was forwarded to Sherri Denton Mallory, Esq., 1008 Harrison Ave, Panama City, FL. 32402, counsel for Hancock, and to Joseph M. Cook, Esq., 42 Business Center Dr., Suite 401, Miramar Beach, FL 32550 Attorney for Cypress Breeze Plantation Homeowners Association, Inc., by fax and regular
mail this 21st day of March, 2012. Respectfully submitted, ___________________________ John Carroll Box 613524 WaterSound, FL 32461 Phone (850) 231-5616
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