, r$h

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DELTSICT{I'

BA\'K }L4,TIOX{AL TRLST

CO\TPA.\f', AS TRUSTEE LNDERTHE POOLING AND SERVICING AGREEMENT

RELATING TO IMPAC SECURED ASSETS CORP., MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-4 PLAINTIFF
VS.

ff

gfil$SA # A #e# ilHffKtr ffi#

LIPHAITE ETNPXUS; LTNKNOWN SPOUSE OF

LIPHAITE AINELUS IF ANY;ANY AND ALL LNKNOWN PARTIES CLAIMING BY, THROUGH, LINDER, AND AGAINST THE HEREIN NAMED INDIVIDUAL DEFENDANT(S) WHO ARENOT KNOWN TO BE DEAD OR ALIVE , WHETHER SAID TINKNOWN PARTIES MAY CLAIM AN INTEREST AS SPOUSES, HEIRS, DEVISEES, z'''.GRANTEES OR OTHER CLAIMANTS: r/'r\ \ ,.

tt

A,

\v-/

nt) ew

L,LANTANA

HOMES HOMEOWNERS

\A

ASSOCIATION, INC.; ELMEZIAAINELUS; /r''\ MORTGAGE ELECTRONIC REGISTRAT IO&*) SYSTEMS,INC., AS NOMINEE FOR /'^

ttl \\/'PossESSroN

AMERICAN BROKERS CONDUIT;JOHN DoE t-' b) AND JANE DoE AS LNKNowN TENANTS tN

{'
COMPLAINT TO FORECLOSE MORTGAGE Plaintiff,
sues the Defendant(s) and alleges:

COLINT I

1. 2. 3. 4.

TIIIS IS AN ACTION to foreclose

Mortgage on real property

in PALM BEACH

County, Florida.

This Court has jurisdiction over the subject matter herein.

On AUGUST 31,2006 LIPI-IAITE AINELUS executed and delivered a Promissory Note and a Mortgage securing payment of the Note to the Payee named thereon. The Mortgage was recorded on SEPTEMBER 8,2006 in Official Records Book 20826 at page 1973, oI'the

Public Records of PALM BEACH County, Florida, and mortgaged the property described in it, then owned by and possessed by the Mortgagors, a copy of the Mortgage and Note are attached hereto as "Exhibit "A"'

5. 6.
1

The Plaintiff acquired the loan which is the subject of the instant foreclosure action prior to the filing of the

Complaint and has the right to enforce the loan.

The property is now owned by the Defendant(s), LIPHAITE AINELUS,

if living and ildead, the unknown

spouses, heirs and beneficiaries of LIPLIAITE AINELUS who hold(s) possession.

There is a default under the tenns of the note and mortgage fbr the DECEMBER 6, 2008 payment and all payments due thereafter.

8.

All conditions precedent to the acceleration of this Morlgage Note and to loreclosure of the Mortgage
been fulfilied or have occurred. The Plaintifl declares the full amount payable undcr the Note and Mortgage to be due. The borrowers owe Plaintiff $228,000.00 that is due in principal on the Mortgage Note and Mortgage,

have

9.

t0.

together with interest lrom NOVEMBER 6,2008, late charges, and all costs o1'collection including title
search expenses fbr ascertaining necessary parties to this action and reasonable attorney's lees.

i l.
12.

Plaintiff is obligated to pay its attorney a reasonable

f'ee

for his services renderecl.

Defendants, .lohn Doe and Jane Doe, may clairn an interest in the property clescribed in the Mortgage as tenants pursuant to a lease agreement, either writtcn or oral. Said interest is sub.ject, subordir.rate, and

infbrior to the lien of the Mortgage held by Plaintilt

tJ.

In addition to all other named def'endants, the unknown spouses, heirs, devisees, grantees, assignees,
creditors, trustees, sllccessors in interest or other parties claiming an interest in the subiect property by,

through under or against any of said defler.rdants, whether natural or corporate, who are not knor.vn to be aliveordead,dissolvedorexistir.rg,are.joinedasdef-endantshereir.r.
subject, subordinate, and inf-erior to the interest
T4,

Theclaimsolanyofsaidparliesar-e

ollrlaintitL

The De1'endant, LANTANA HOMES HOMEOWNERS ASSOCIATION, INC., is joined because it rncy

claim some interest in or lien upon the subject property by virtue olpossible associatior.r liens and
assessments. Said interest is sub.iect, subordinate, and inl'eriorto the lien olthe Mortgage held by the

Plaintiff.
15.

The Defendant, UNKNOWN SPOUSE OF LIPHAITE AINELUS, is joined because SHE may claim some interest in or lien upon the subject properly by virtr.re

ola possible homestead interest.

Saicl intcr.est is

subiect, subordinate and inf'erior to the interest of the Plaintiff's ntortgage.

t6.

The Def'endant(s), ELMEZIA AINELUS, is joined because shc may claim some interest in or Iien upon the subject property by virtue of a POSSIBLE INTEREST PURSUANT TO EXICUTING TFIE MORTGAGE recorded in PALM BEACII County u,hich is inferior to Plaintilfs Mortgage describec'l hereir.r.

t].

The DefendaTTt(s), MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC., AS NOMINEE FoR

AMERICAN BROKERS CONDUIT, is.ioined because it may claim some interest in or lien
subject property by virtue

r-rpon the

ola MORTGAGE, recorded in Ofllcial Records Book 20826 at Page 1995 in

hereir.r.

PALM BEACH County r'vhich is inf'erior to Plaintiff's Mortgage described

WHEREFORE, Plaintiff prays: That an accounting may be had

ar-rd

taken under the direction of this Court

of what is due the Plaintiff for principal and interest on said Mortgage and Mortgage Note, and fbr the costs, charges
and expenses, including attorney's f'ees and title search costs, and advancentents which Plaintiflmay be putto or

incur in and about this suit, and that the Defbndants fbund responsible fbr same be ordercd to pay tho PlaintifTherein
the amounts so found to be due it; that in def'ault olsuch paynlents, all right, title, interest, claim, clcmand, or equity

of redemption olthe Defendants and all other persons claiming by, through, undcr or against said Def-endants since
the filing of the Lis Pendens herein be absolutely barred and foreclosed and that said mortgage property be sold

rrltqlq

:!..Ti.:Fj\!{n\rT
SERIES

ltlf6--{ v. LtPll\ITE .\FELLS. ET.\r

i,l*!,::\ra

11:

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sE:--Es q,iiE:5

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. p$:I{::,r4ffi

4ss Timal:rLfi:rfit 3wrrssKM]rllr$$;

under the direction of this Court; that out of the proceeds of said sale, the amounts due the Plaintiff may be paid so

far as same will suffice; and that a deficiency judgment be entered if applicable and only in the evenr no Order of Dischalge ofPersonal Liability in Bankruptcy has been entered as to any ofthe Defendants who signed the subject Note and Mortgage and a Writ of Possession be issued.

TO ALL DEFENDANTS: PLEASE NOTE EFFECTM OCTOBER 13,2006,15 U.S.C. $1692c OF THE FAIR DEBT COLLECTION PRACTICES ACT HAS BEEN AMBNDED AS FOLLOWS:
(a) LEGAL PLEADINGS -- Section 809 of the Fair Debt Collection Practices Act (15 U.S.C. f 6929) is amended by adding at the end the following new subsection: "(d) Legal Pleadings -- A communication in the form of a formal pleading in a civil action shall not

SOLOMON
Bar #:842540

l[$,r\\d)\

10-30391 CWF

Miriam Mendieta Bar #: 0866880 Law Offices of David J. Stern. P.A. Attorney for Plaintiff 900 South Pine Island Road, Suire 400 Plantation, FL 33324-3920 (954) 233-8000

Under Penalty of Perjury, I,

as authorized signatory on behalf

ol

SERVICING AGREEMENT RELATING TO IMPAC SECURED ASSETS CORP.. MORTGAGE PASS. THROUGH CERTIFICATES, SERIES 2006-4. declare that I ng, and the facts alleged therein are true and correct to the best of my knowledge and belief

NAME:

Vi,pe Frgpidsrx*

F:\GROUPS\FCDOCS\COMPI-AIN\

0\l 0-3039 LCMP

L\[

Tt[emcurTgruurtr"m
N A\D

FOR PAL,tl BE;qCll C[|Ll![Ty- SLOmmU[

CIITL DN-ISIO\
WELLS FARGO BANK, NATIONAL ASSOCIATION, Case No': AS TRUSTEE FOR MORGAN STANLEY ABS CAPITAL I INC. TRUST 200'/-HE4 MORTGAGE Division: PASS-THROUGH CE,RTIFICATES, SEzuES 2OO7-HE4 Plaintiff,
vs.

ROSANNA SOLIS, ET AL.,

Defendants.

VERIFICATION OF FORECLOSURE COMPLAINT

Under penalty of perjury, I declare that I have read the foregoing Mortgage Foreclosure Complaint and the facts alleged therein are true and correct to the best of my knowledge and belief'

BANK OF AMERICA, N.A. as Attorney in Fact foT WELLS FARGO BANK, NATIONAL ASSOCIATION, AS TRUSTEE, FOR MORGAN CAPITAL I TNC. TRUST 2OO7E PASS-THROUGH

200't-HE4

Title:

IN T}TE CIRCIITT COURT OF TTIE FIFTEENTH

JUDICIALCIRCUITINANDFoRPALMBEACHCOUNTY,FLORIDA
CTVIL ACTTON

BANK OF AMERTCA, N.A.' Plaintiff'

vs
Defendant(s)
I

CASE NO.

ryffifi1;$0^t$R&*#ffiff*

SUMMTTONKAENTERPRISES,LLC,;WLLIAMJ.STODDARD;ANYAND AND AGAINST THE HEREIN NAMED INDIVTDUAL PARTIES CLAIMING BY, THROUGH, UNDER'

DEFENDANT(S)wHoannNorKNowNToBEDEADoRALIVE,WI{ETHERSAIDUNKNOWN PARTTESMAYCLAIMANINTERESTASSpOUSnS'HEIRS'DEVISEES',GRANTEES',OROTHER ASSOCIATION' INC'; TENANT #l', TENANT cLAIMANTS; Crrvpr,lcc TOWER CONIOITNIUM to account for parties in possession
fictitious #2, TENANT #3, and TENANT #4 the names being

VenrrrcartoN oF FoREcLosuRE coMPLAINT

Uncler penaltY

or

Perjury,

ldeclarethatlhavereadtheforegoingComplaintlrledagainstSUMMITONKA
correct to the best of my knowledge and a1., and the facts alleged therein are true and

&ffi'

ENTERPzuSES, LLC,;, Et belief.

BANfdF A[\{ERICA, N'A.

BY:

F-:1

cat
.;P '-l-

Title:
As
Date:

Print Na
(.

r$r cr}
-,{{=':-

the:

f/r /rs/o

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F10029450


! ryER-.I .t?-lsilCT],rt*\ }tt \O;

BACHOMELOANSSM
coLNTRywrDE HoME LoANS sEnvicnvc
LP

CASE

tS,.r,

t,[*

,4p $s [$1$ eA fl 23 3 0 n xKXX $?fi

PLAINTIFF
r. *ltr" i {I
.,

cR_EENS HoMEowNERS
I

INTEREST AS SPOUSES, HEIRS. oA,ViiEUS, cRANTEES oR orHER cr,arl.raiisAloce

LNKNOWN PARTIES UAV CT.AIV'AX

HEREIN NAMED INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE DEAD oR ALrvE, wuErnEdiain '

THRoucH, LTNDER, AND AGArNsrine

ANN TRACEv;'#rEn J. TRACEy ^ A/wA pErER TRACEy; axv axn LNKNOWN PARTTES Crervrxc

nv]"

eif

LUA\s. INc.JoHN ooE eNn?nNE DoE uNKNowN TENANTS rN possnsloN -"

NC';fv{ORTCAGE ELECTRONIC REGIS RATION SYSTEMS, IItrC., AS f^oMrNEE FOR COLfNTnywrDe

ASsocraiio

,)
t "' . "..:i
,

'iJ

-a-.!
'j

sour

-''-i

AS

i:J

COMPLAINT TO FORECLOSE MORTGAGE

prainrit)_. sues the Defendant(s) and

alleges:
in pALM BEACH county,

l
)

;ij COUNT I THIS ls AN ACTION to foreclose a Mortgage on real property

This Court has j urisdiction over the subj ect n.ratter herein. on MARCH 9' 2007 PETER J' TRACEY AND FAITH Note and a PURCHASE

Florida.

ANN TRACEy executed and derivered

M'NEY

;:Tj:"" '1'
The Mortgage was recorded on

Mortgage securing paymenr of the Note to the payee named

5'

6'

'

interest prior to the filing of this complaint. The property is now owned by the Defendant(s), FAITH AN'N TRACEY AND PETER J. TRACE' AII</A PETER TRACEY' if living and if dead, the unknown spouses, heirs and beneficiaries of FAITH ANN TRACEY AND PETER J. TRACEY A/WAPETER TRACEY There is a delault under the terms of the note and mortgage for the SEPTEMBER payments due thereafter.
WhO hOId(S)
POSSCSSiON.

as Plaintiff' as seryicer for the owner and acting on behalf of the owner with authority to do so, is the present designated holder of the note and mortgage with authority to pursue the present action. plaintiff held this

16,2007 in officialRecords Book 2l 524 atpage4g0, of the Public Records of PALM BEACH county' Florida, and mortgaged the property described in it, then owned by and possessed by the Mortgagors' a copy of the Mortgage and ,,Exhibit Note
are attached hereto
,,A,,.

MARCH

l,2.,gpayment and all

(illlf

,!fitllr
r rrllrilllll

rllllttrl

!
9.
10.

-q-. :,:rir::::!.:i ?r-sced.r:-::": --:ie been fulfilled or have occurred.

:;as--:ii.Lri !-::1s \Icngage \o:e ano Io ibreciosure of the \Iortgage have

The Plaintiff declares the full amount payable under the Note and Mortgage to be due. The borrowers owe Plaintiff $391'920.00 that is due in principal on the Mortgage Note and Mortgage, together with interest from AUGUST 1,2009,1ate charges, and all costs of collection including title search
expenses for ascertaining necessary parties to this action and reasonable attorney,s f'ees.

11.

Plaintiff is obligated to pay its attomey a reasonable fee for his services rendered.
Defendants' John Doe and Jane Doe, may claim an interest in the property described in the Mortgage as tenants pursuant to a lease agreement, either written or oral. Said interest is subject, subordinate, and

t2.

inlerior to the lien of the Mortgage held by plaintiff.

13.

In addition to all other named defendants, the unknown spouses, heirs, devisees, grantees, assignees, creditors, trustees, sucaessors in interest or other parties claiming an interest in the subject property by, through under or against any ofsaid defendants, whether natural or corporate, who are not known to be

aliveordead,dissolvedorexisting,arejoinedasdefendantsherein.
subject, subordinate, and inferior to the interest ofplaintiff.
T4,

Theclaimsofanyofsaidpartiesare

The Defendant,

BocA GREENS HoMEowNERS ASSoclATIoN,INC,,

is

joined because ir may claim

some interest in or lien upon the subject property by virtue of possible association liens and assessments. Said interest is subject' subordinate, and inferior to the lien of the Mortgage held by the plaintiff. t5.
ThC DEfCNdANI(S), MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC., AS NOMINEE FOR

joined because it may claim some interest in or lien upon the subject property by virtue of a MoRTGAGE recorded in officialRecords Book 21524 at page 504 in PALM BEACH county which is inferior to plaintiffs Mortgage described
is

COUNTRYWIDE HOME LOANS, iNC',

herein.

herein the amounts so found to be due it; that in default of such payments, all right, title, interest, claim, demand, or equity of redemption of the Defendants and all other persons claiming by, through, under or against said Defendants since the tiling of the Lis Pendens herein be absolutely barred and foreclosed and that said mortgage propefty be sold under the direction of this court; that out of the proceeds of said sale, the amounts due the plaintiff may be paid so far as same will suffice; and that a deficiency judgment be entered if applicable and only in the event no order of Discharge olPersonal Liability in Bankruptcy has been entered as to any of the Defendants who signed the subject Note and Mortgage and a Writ of possession be issued.

WHEREFORE, Plaintiff prays: That an accounting may be had and taken under the direction of this Cor"ut olwhat is due the Plaintiff for principal and interest on said Mortgage and Mortgage Note, and for the costs, charges and expenses, including attorney's fees and title search costs, and advancements which plaintiff may be put to or incur in and about this suit, and that the Defendants found responsible for same be ordered to pay the plaintiff

To -{LL DEFEIiD.\NTS; pLEASE NorE EFFECTT\T ocroBER 13,2006,15 u.s.c. $1692c oF THE FAIR DEBT COLLECTION PR{CTICES ACT HAS BEEN AMENDED AS FOLLOWS:
(a) LEGAL PLEADINGS -- Section 809 of the Fair Debt Collection Practices Act (15 U.S.C. 16929) is amended by adding at the end the following new subsection: "(d) Legal Pleadings -- A communication in the form of a formal pleading in a civil action shall not be treated as an initiar communication for purposes of subsection (a).,,

t
OSEPH Bar #: 6

ffttttlri

7;+l?

Miriam M Bar#:0866880
Law Offices of David J. Ster.n. p.A. Attorney fbr Plaintiff l0-32989 CWF
900 South Pine Island Road. Suire 400 Plantation, FL 33324-3920 (954) 233-8000

Under Penalty of Perjury, I, as authorized signaror.y orr behalf of BAC HOME LOANS SERVICING LP F/WiC'OUNTNVWIDE HOME LO ERVICING LP, declare rhat I have read the fbregoing, and the facts alleged therern are true and correct of my knowledge and belief.

NAME:

As"*e$f*

, :illdili"l 1r]i
lll'

{N&ruleiltilli!illllutsl[tr,

lrlin illLllll{{ll],ilii,,[m

frr.rul]Jffii,fim,r]liw0lmlllll{nmmruillillml

F,LrLttlffllffi'c

GF!E]K{- .:*R-S};CIO\ Dft'lSIO\

C.ISE

\O:

BAC HOI.TE LOANS SERVICING, LP FKA COT]I{TRYWIDE HOME LOANS SERVICING.

TP

AV

F0
PLAINTIFF

2010 CA CI ?3 3

CI

XXXI{rdru

t {4; \-JouN MCCANN: uxkKbwN spousr

,-JlCAPITAL ONE BANK (USA). Nn!V+og' oo' -" ANIftANE DOE AS LINKNOWN TENAN'TS IN
POSSESSION

t'lF JOHN MCCANN IF ANY;ANY AND ALL LTNKNOWN PARTIES CLAIMING BY, THROUGH, UNDER, AND AGAINST THE HEREIN NAMED INDIVIDUAL DEFENDANT(S) WHO ARE NOT KNOWN TO BE DEAD OR ALIVE. WHETHER SAII) UNKNOWN PARTIES MAY CLAIM AN INTEREST AS SPOUSES, HEIRS, DEVISEES. CRANTEES OR OTHER CLAIM{NTS;

VS.

COMPLAINT TO FORECLOSE MORTGAGE Plaintifl, sues the Defendant(s) and alleges:

COLINT I
tr\rl_

r r'1,1

', a\

J
County, Florida.

1' 2.
3.

THIS IS AN ACTION to foreclose a Morlgage on real properly

This Court has jurisdiction over the subject matter herein.

in pALM BEACH

On DECEMBER 12,2006 JOHN MCCANN, A MARRIED MAN, AS HIS SOLE AND SEPARATE

PROPERTY executed and delivered a Promissory Note and

the Payee named thereon.

a Morlgage

securing payment of the Note to

official Records Book 2 1242 atpage 193g, of the Public Records of PALM BEACH County, Florida, and mortgaged the property described in it, then owned by and possessed by the Mortgagors, a copy of the Mortgage and Note are attached ,,Exhibit ,'A,,.
hereto as

The Mortgage was recorded on DECEMBER 28,2006 in

servicer fbr the owner and acting on behalf olthe owner with authority to do so, is the present designated holder of the note and mortgage with authority to purslre the present plaintiff held this action. interest prior to the filing of this complaint.
as

Plaintiff,

The property is now owned by the Defendant(s), JOHN MCCANN,

if living and if

dead, the unknown

spouses, heirs and beneficiaries of JOHN MCCANN who hold(s) possession.

There is a default under the terms of the note and moftgage lor the JULY due thereafter.
8,

l,

2009 payment and all payments

precedent to the acceleration of this Mortgage Note and to fbreclosure of the Morlgage have been fullllled or have occurred. The Plaintiff declares the full anount payable under the Note and Mortgage to be due.

All conditions

9.

E
F

-_-.:r--::_11 :., __,r lT{:,aizua \:i_ tt:r: l_l:L_-le:, togetheruithinterestliomJL\E 1,1009, latecharses.andallcostsoicollectioninclucingririesear;h
expenses for ascertaining necessary parties to this action and reasonable attorney,s t'ees.
11.

Tlri ft':ti-.'ri:s.i-ne P::::t:::5:!r-4.:i::.::.s;r-

Plaintilfis obligated to pay its attorney a reasonable lee tbr his services rendered.
Defendants, John Doe and Jane Doe, may claim an interest in the property described in the Mortgage as tenants pursuant to a lease agreement, either written or oral. Said interest is sub.ject, subordinate, and

12.

inferior to the lien of the Mortgage held by plainriff.

13.

In addition to all other named defendants, the unknown spouses, heirs, devisees, grantees, assignees, creditors, trustees, sllccessors in interest or other parties claiming an interest in the sub.ject property

by,

through under or against any olsaid defendants, whether natural or corporate, who are not knowr to be alive or dead, dissolved or existing, are joined as defbndants herein. The claims of any of said parties are subject, subordinate, and int-erior to the interest ofplaintiff.

t1.

The Defendant'

uNKNowN sPousE oF JoHN MCCANN,

is

joined because SHE may claim some

ola possible homestead interest. Said interest is subject, subordinate and inferior to the ir.rterest of the plaintiffs mortgage.
15

interest in or lien upon the subject propefiy by virtue

The Deflendant(s), GAPITAL oNE BANK

(usA), NA,

is

joined because it may claim some interest in or

lien upon the subject property by virtue of a FINAL.IUDGMENT recorded in officialRecords Book 2306g at Page 1240 in PALM BEACH County whrch is inf-erior to Plaintiff-s Mortgage
described herein.

ordered to pay the herein the amounts so fbund to be clue it; that in default of such payments, all right, title, interest, clairn, demand, or equity of redemption olthe Defer.rdants and all other persons claiming by, through, under or against said Defendants since the filing olthe Lis Pendens herein be absolutely barred and loreclosed and that said morlgage property be sold under the direction of this courl; that out of the proceeds olsaid sale, the amounts due the plaintilf may be paid so lar as same will suffice; and that a deficiency.iuclgment be entered if applicable and only in the event no order of Discharge of Personal Liability in Bankruptcy has been entered as to any olthe Defendants who signed the subject Note and Mortgage and a Writ of possession be issr-red.

WHEREFORE, Plaintiff prays: That an accounting may be had and taken under the direction of this Courl of what is due the Plaintifr lor principal and interest on said Mortgage and Morlgage Note, and fbr the costs, charges and expenses, including attorney's fees and title search costs, and advancements which plaintiff rnay be put to or incur in and about this suit, and that the Defendants found responsible for same be plaintiff

-riltt]lllt1ilil!ilrtltldlU.l0ilNilf1" "lllllflm

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li,

lmmM[imlElfi{ufi[lf,rr mr'ryllj]L

PLEASE NOTE EFFECTIIE OCTOBER 13,2006, 15 U.S.C. $r692c oF THE FAIR DEBT COLLECTION PRACTICES ACT HAS BEEN AMENDED AS FOLLOWS:
(a) LEGAL PLEADINGS -' Section 809 of the Fair Detrt Collection Practices Act (15 U.S.C. 16929) is amended by adding at the end the following new subsection: "(d) Legal Pleadings '- A communication in the form of a formal pleading in a civil action shall not

TO ALL DEFENDANTS:

Bar #:52874 6.r Miriarn Mendieta

rvr^ r l nf:. vY t . SHAPANKA )nArAl\llA

GtY

/-\,

l0-32383(CWFXFNM)

Bar #: 0866880 Law Olfices of David J. Stern. p.A. Attorney for Plaintifl' 900 South Pine Island Road. Suirc 400 Plantation, FL 33324-3920 (9s4) 233-8000

Under Penalty of Per-jury, I,

, as authorized signatory on behalf of BAC

read the fbregoing, and the facts allegecr therein are true and correct to the

iERnrc;ric, #,

y knowledge and belief.

;.;il;;; ;;;

NAME:

Smsxs:mda

IN THE CIRCUIT COLIRT OF THE FIFIEE}ITH ILDICIAL CIRCt1UTIN AND FOR PALM BEACH COLINTY, FLORIDA CNIL DIVISION
DE,LITSCHE BANK NATIONAL TRUST

COMPANY,

CASE

NO':

fi3J5Hi3t?H,3RHtit3+;+f&'#H'ffi'r Dimmom$ t I
2OO

2 t ilxffi ilF

MORTGAGE PAS S-THROUGH CERTIFICATES, SE,RIES 2OO4-HE4 Plaintiff,

4 -HE4
VS.

JAMES M.I]OPKINS JR. A/K/A JAMES M. I{OPKINS, ET AL.,

Defendants.

VERIFICATION OF FORECLOSURE

COMPLAINT
r ,1.-'-:.' :rl .l

- -i t:']
L,a*

Under penalty of perjury, I declare that I have read the foregoing Moftgage

ForbibiUie
* .-- a,:
_iie

$
:t"-"'

Complaint and the facts alleged therein are true and correct to the best of my knowledg+arl{

lie$ -,1 tf r'":l'

:-:"'

BANK OF AMERICA, N.A. as Attorney in Fact foT DEUTSCHE BANK NATIONAL TRUST COMPANY, AS TRUSTEE ON BEHALF OF THE CERTIFICATE HOLDE,RS OF IXIS REAL

-]t.,,

ES 2OO4-HE4

By:

Title:

AnslakntWee presidenf

BA6699- 10/cg