thy yl a + IN THE CIRCUIT COURT FOR DUVAL COUNTY. FLORIDA. CIVIL DIVISION CASE NO. FEDERAL NATIONAL MORTGAGE ASSOCIATION, oo THe 223 HXXX-MA Plaintiff, “Lone, ENCINOSA; bas T MARSH, e \Sane ae Cj an INC; JPMORGAN FHASE BANK, N. v |THE CIRCUIT COURT OF DUYAL Ci - FLORIDA; THE STATE OF FLORIDA: NES; UNKNOWN TENANT NO. 1; JNKNOWN TENANT DIVISION FC-H NO, 2; and ALL UNKNOWN PARTIES CLAIMING INTERESTS BY, THROUGH, UNDER OR AGAINST ‘A NAMED DEFENDANT TO THIS ACTION, OR HAVING OR CLAIMING TO HAVE ANY RIGHT, TITLE OR INTEREST IN THE PROPERTY HEREIN DESCRIBED, RK OF Defendants. / COMPLAIN The Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION, sues the Defendants, ADRIENNE C. ENCINOSA; VILLAS AT MARSH LANDING CONDOMINIUM ASSOCIATION, INC.; JPMORGAN CHASE BANK, N.A.; THE CLERK OF THE CIRCUIT COURT OF DUVAL COUNTY, FLORIDA; THE STATE OF FLORIDA: R.L. HAINES: UNKNOWN TENANT NO. 1; UNKNOWN TENANT NO. 2; and ALL UNKNOWN PARTIE! CLAIMING INTERESTS BY, THROUGH, UNDER OR AGAINST A NAMED DEFENDANT TO THIS ACTION, OR HAVING OR CLAIMING TO HAVE ANY RIGHT, TITLE OR INTEREST IN THE PROPERTY HEREIN DESCRIBED, and alleges:NERAL ALLEGATIONS 1. JURISDICTION: This is an action for equitable relief or, alternatively, for damages, which claims are within the subject matter jurisdiction of this Court. VENUE: This is an action that involves parties and property located within the venue of this Court and venue is otherwise proper pursuant to Chapter 47, Florida Statutes. 3. PARTIES: All parties to this action are properly before this Court and this Court has n over the parties. DENT: All conditions precedent to the filing of this action have been met by Plaintiff. 5. EDCPA: Plaintiff hereby provides Defendant(s) with verification notice as required under the Fair Debt Collection Practices Act (“FDCPA”) 15 U.S.C.A. 1692. If the Defendant(s) request verification of the debt, Plaintiff shall suspend its efforts to collect the debt until Plaintiff mails the requested information to the Defendant(s) requesting the verification. A copy of the notice is attached hereto as Plaintiff's Exhibit “A”. 6 LOSURE ACTION: This is an action to foreclose a mortgage on real property (hereinafter the “property”) in Duval County, Florida, more particularly described in the mortgage attached hereto as Exhibit “B” 7. EXECUTION AND DI IVERY_ OF NOTE & MORTGAGE: On May 13, 2005, Defendant(s), ADRIENNE C. ENCINOSA executed and delivered a promissory note (the “note”) and Defendant(s), ADRIENNE C. ENCINOSA executed and delivered a purchase money mortgage (the mortgage”) securing payment of the same to Mortgage Electronic Registration Systems, Inc., acting+ solely as a nominee for Lehman Brothers Bank, FSB, which mortgage was recorded in Official Records Book 12504 Page 2045, of the public records of Duval County, Florida, and which mortgaged the property. The property was then owned by and in possession of the mortgagor. 8 OWNERO THE NOTE & MORTGAGE: The note was subsequently transferred to Plaintiff, Plaintiff owns and holds the note and mortgage. 9. OWNER OF THE PROPERTY: The Defendant(s) ADRIENNE C. ENCINOSA, own(s) the property 10. DEFAULT & ACCELERATION: The Plaintiff has not been paid the payment due December 1, 2009, and all subsequent payments, which has resulted in a default of the note and mortgage. Plaintiff declares the full amount due under the note and mortgage to be accelerated. 11. AMOUNTS DUE: The Plaintiff is owed $127,969.33 that is due as principal on the note and mortgage, interest from November 1, 2009, costs, advances and expenses as provided in the note and mortgage. 12. ATTORNEYS FEES: Plaintiff has obligated itself to pay the undersigned attorneys a reasonable fee for their services herein and is entitled to recover said fees pursuant to the terms of the note and mortgage. INFERIOR CLAIMAN’ 13. Defendant(s), VILLAS AT MARSH LANDING CONDOMINIUM ASSOCIATION, INC., may claim some interest in the subject property arising from unpaid assessments. This interest, if any, is inferior to Plaintiff's mortgage. 14. Defendant(s), JPMORGAN CHASE BANK, N.A., may claim some interest in or lien upon the subject property arising from a mortgage, recorded in Official Records Book 12504 Page 2071, inferior to Plaintiff's mortgage. of the public records of Duval County, Florida, which mortgage is