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Rodriguez, Gloria - Case #18-043 - Foreclosure (Released)PREPARED BY AND RETURN TO: City of Okeechobee Code Enforcement Department 50 Southeast 2°d Avenue Okeechobee, Florida 34974 Official Redt�antt File#'L021003587 Page(s):1 Jerald D Bryar�t Clerk of the Circuit Court & Comptrdler Okeechobee, FL Recorded 3/24l2021 2:04 PM Fees: RECORDING $1Q.00 RELEASE OF LIEN The City of Oke�chobee ("City"), is the owner and holder of the Lien/Order recorded on August 2, 2019 in OR Book 828, Pages 1250-1251 of the Official Records of Okeechobee Co.unty, Florida, claiming a lien against the property described as follows: City Case No Site Address 18-043 914 NW 2°d Street, Okeechobee, Florida 34972 Legal Description: Lot 17 and East %2 of Lot 16, Block 132, Town of Okeechobee, according to the plat thereof recorded in Plat Book 2, page 17, Public Records of Okeechobee County, Florida Parcel ID No: 3-15-37-35-0010-01320-0160 ("Property"). The City hereby fully releases said Lien/Order against the Property and considers same to be cancelled and discharged of record. While this Release of Lien is intended to fully and completely release the aforementioned Property from the Lien/Order, it is not intended to release or embrace contractual rights. City of Okeechobee �� i Dowling R. atford, Jr., Mayor 3-L� - •Z/ Date Sworn to (or affirmed) and subscribed before, by means of [v]�physical presence or ❑ online notarization, me this � day of March, 2021, by �j �►� � �' I r, who is � personally known to me or ❑ provided the follo ing 'de tification: No bl' - State of Florida NOTAR P BLIC �o?�;;P�s� BOBBIE JO JENKINS State of Florida at Large * *�m�� t GG ��35i8 My Commission Expires: N�'��.o� Expires March 24, 2o2a ,FOFFi�P BMd1/ThV�U��Efli�iily$MYiI'R9 � I1�I TH� COUNTY C�URT OF THB NINETEENTH JUD[CIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CASE NO.: 472020CC000190CGAXMX CITY OF OKEECH�BEE, FLORIDA, a municipa] cc�rporation organized under the laws of the; State of Flo�•ida, Plaintiff, v. GLORiA RODRiGUEZ, RAUL RODRIGUEZ, and NOE ROI'1RTGUEZ, Defendants, SETTLEMENT AGREEMENT THIS SETTLEMENT AGREEMENT ("Agreement") is deemed made and entered inta on February , 2021, by and between the parties, CITY OF OKEBCHOBEE, FL�RIDA ("City" or "1°iauitifP') and GLORIA RODRIGUE2, PAUL RODRIGUEZ, and NOE �ODRIGUEZ (collecfiveiy "Rodrzguez" or "Defendants") (colleckively the City/Ptaintiif and RodriguezJDefendaizts axe the "Parties"), in Okeechobee Couniy, Florida. WITNESSETH WHEF�AS, the. City initiated a code enfoxcemet�t proceeding with regard to pxopex�ty located 914 N.W. 2"d Street, Qkeechobee, Floxida 32643-6403 {"Property"}; and, WHE1gEAS, the code ex�orceznent proceeding resulted in a Lien/Order being issued imposing a�ne af $25.0� per day; and, WH�REAS, the City issued a letter dated October 1, 20i9 advising Rodriguez that the daily fines accrued for over 90 days and that a foreclosure actian could be pursued; and, R WFIEREAS, Rodrigtzez's failure to pay the fi�es and remediated the Property resu(ted in th:e City filing a municipal lien foreclosure action on November 2, 20Z0; and, WHE�AS, the Parties mutually desire to resolve their differences by entening inta thzs Agreement; and, WHEREAS, each of the Parties herefo has had an opportunity to rece'rve independent legaI advice as to the nature and obligation of the Parties, each to the other, particularly in re%rence to this Agreement, and each has had an opportunity to become fully informed of his or her respective legal rights, obligations, liabilifies and dnties; and, WI3EREAS, each of the Parties believes #hat this Agreement is fair, just and reasonable, and each has assented freely and �voluntarily to all of its terms without pressure, duress or coercion. Neither has made any promises to the oilaer to induce him/her ta enter into this Agreement and both Parties intend to be legally bound by the terms and conditions herein. NOW, THEREk'4RE, in consideration af the nautual covenants, promises, terms and conditions herein contained, and for oiher gaod and valuaUle considerations each to the otl�er given, receipt and sufficiency of which is acknowledged, it is mutuaIly eovenanted, promised and agreed between the Wife and Husband as fol]ows; 1. RECITALS. The above recitals are true and correct and are incorporated in their entirety by reference into this Agreement. 2. ADEQUACY OF CONSIDERATION. The consideration for this Agreement is tl�e mutual benefits obtained by the Parties and.the promises made by each to the other. The Parties admit the adequacy of consideration for this Agreement. 3. REPRESENTATI�N BY COIJNSEL. Each party has had the opporiuniiy to be t represented by indepez�dent legal counsel oi their own selection in the negotiatian of this i Agreement, `�'he City is represented by R. Gregory Hyden, Bsq. and Rodriguez is represented hy Colin Camercrn, Esq. The Parties unde�stand the facts and ternns of this Agreemeni and have had adequate opportunity to becorne fully informed as to their Legal rights and obiigations and each is szgning this ��greement freely and voluntarily, intending to be bo�and by it. This Agree�nent is entered withorai undue influence, fraud, collusion or misrepresentation. 4. REM�DIATION OF THE PRO�ERTY. As of the date of this Agreement, Rodriguez has already pracured th� necessary City permits and has dez�olished fihe dwellings on the Pxoperiy, Thus, the Parizes acknflwledge and agree that aIl previously existing City Code violations have been cured. S. PARTI�S ATTORNEY'S FEES. The Parties acicnowtedge and agree that the Rodriguez's shall pay the City the sum of $11,355.74 ("Settlement Surn") in full, complete acco�cd an,d satisfaction of the accrued fines, including $3,993.25 as and for its attomey's fees and eosts incurred in this action_ Settlement Sum shali be paid by certified fnnd.s no later than fftcen (15) days from the date of this Agreernent. Within five (S) days irom #he date the City receives the Settlement Surn, the City sI�a11 file a Notice of Dismissal in this action. . 6. MUTUAL RCPRESENTATIONS. The Parties represent to each other that each �utderstands and agrees that this Agreement constitutes the entite coniract of the Parties. It supersedes any priox understanding or oral agreements between them. Thus, any addenduin modificativn or waiver of any of the terms of dlis Agreement shalI not be effective unless it is expressed in an insiru�nent of equal dignity by the Parties. 7. B�NEFIT. Ail of the provisions of this Agreement shall inure to the beneiit af and shall be binding upon the ParEies, unless otherwise stated herein. r �: S. JURISDICTION AND VENU�. Florzda law shall govern the r�a(idity, constrnction, interprefiation and effect of this Agreemeni. The Parties agree that the courts of com�eient jurisdiction sitiing in the Circuit Court of the Nineteenth Judicial Circuit, in and for Okeechobee County, Florida shall have excl�zsive jurisdiction ix� any suit by the Parties to enforce their xights hereunder, and that venue is praper in that court. 9. COUNTEItPA.RTS. This Agreement may be signed in one counterpart signaEvrs or more counter}�arts each of wbich, wiaen executed with the same foi7nality and the same manner as the original, shatl constitute an original. 10. FA.XLURC TO ENFORCE. Each of tha provisions of this Agreement axe sepaxate and independent af one another. Either party may insist upon the waiver of or the right of any party to compel performance of another provision of this Agreerrient. li any provision of this Agreenaent is held by a Court of competent jurisdiction to be va�id or unenfarceat�le, the remaining provisions shall continue in full force and effect without being innpaired or invalidated in any way. However, the Cou.rt having juz-�sdiction may adjust the equities herein to accomplish the intent of the Parties as to any provision held inva.iid or unenforceable. l l. SEVERA.BILITY. Each of the provisions of tt�is Agxeement are separate and independent of one another. Bither party may insist upon the enforcement of any provision af this Agxeenaent without insistence upon the waiver o:f or the right of any party to compel performance of another provision of this Agreement. If any pravision of this Agreement is hald by a Court of ca�npetent jurisdiction to be invalid or u.nenforceable, the remaining provisions shall continue in full force and effect without being impaired or inva[idated in any way. However, the Court having � jurisdiction may adjust the equities herein to accomplish the in#ent of the Parties as to any provision held invalid o�� unenforceable. I2. SURVXVAL. Any and all of the terms and provisions o;F tl�is Agreement shatl survive the execution and delivary of this Agreement and shall coiztinue in force and effect ��a��F��t�iy. 13. ENFORCEMENT OF AGREEMENT. The Circuit Court having jurisdiction ovez� this cause: shall retain jurisdiction to enforce alI of the terrns and provisions of this Agreement artd fhe Final Judgment in tktis cause sha]I contain an express provision for the Court to retain jurisdic#ion fox that purpose, 14. ENTIRE AGRE�MENT. `The parties actcnowledge that this Agreement contains the fuIl and complete agreement between and arr►ong them, and that thet�e are no oral or implied agreements or understandings nof specifically set forth herein. Each party acknowledges that no other party, or attorney of any other paz�ty, or ar�y person, iirm, corporation or any othar entity has nzade any promise, representation, or warzaniy, whatsoever, express, implied, or statutoty, nat contained herein, conoerning the subject maiter hereof, to induce the execution oithis Agzeement. 15. MODIFiCATION. The parties agree that na modi�cations of this Agreerxkent may be made unless expressly agreed to in writing by t�e Parties. 16. PAR,A.GRAPH HEADINGS. The headings of the paragraphs of this Agreement are ivaserted only for the purpose of convenience af reference, and the parties recognize az�d agree that these headnngs rnay not adequately or accurately describe the contenfs ofthe paragraphs which they head. Such headings shail not be deemed to govern, limit, modify or in any manner affect the scope, meaning or intent of the provisions af this Agreement ar any part or portion thereof, nor shail they otherwise be given any legal ef%ct. . , �N Vi�ITNESS WH�R�OF, the parties hereto have personalty executed this Agreement or have caused this AgreemenY to be executed by a dttly autliotxzed officer and/or agent. FURTHER AFTIANT SAYETH NAUGHT. DATED: 2. `) p, 21 DATED: Z�� ' �� zs�� ! .._��____.--- RAUL RODRIGUEZ, individvally and CO N CAMERON, ESQ, On behalf of Glaria and Noe Rodriguez Counsel for the Rodriguez's per verba� authorization DATED: o'l -a3 - a,o 2v� � '.; ' , DATED: . i � / ..� � c.�l�� A • ♦; �• j �''' ' ` ` �„ l� FF. GREGORY HYDEN, ESQ., Counse`l f City �, .� . � , ` , . �- �;� 3-':::* �El e��'vsn'�`�oGs� q' ;��7`v �7i�<v�.�l�'� 3 ; ::Ord�*r Of `• �y` . . / �.. S� , �../' i % �� 3 . �% ... `l " �i:� � � %' .. :9 . ..:..<..T[. �' �• �ti ' �s f, /:{' �' . .��..:' �+�...,�.;v.•;.r � . ii%. "�%r.r.�.^ j.:"}> . .ris.�� .�.'ji i�•, ` RNr� as ` 'g ..Rt4t[IC. R DAI�U£�•7.. ! ;.; � i '7remiiter,( �r ed �.�: Q z ,� ",��,; ',�''` �` .'q� ,'•w" 'r , t f( ,; .<ks -`.,,_ 'f. .��'�_y:;: :� !''t�. ' : f Y ��;,� .} �: Ba�c of �Ameri�a,%N.A.: � _ , . � ' r. ' i : J � S ;�� v,.�A1V %INTO;�fta; �'3C .. . ..,,- t` , . .,., _ _ ; � , , ! •,.t' ?; . , .... ,, i .� � ♦.J ..... i�. � .. . .i .� .w .. . n. �.yi . .'.'l�, .v... �4..vi.F� ... ... i�. :[�r u� LO i'�6 1D�54i�' �:1 �4000d i9�: C10 LE,4 i�C}O i9 93n• �<:'7HE;OA14(�7C1:'UOCUMENT�ltAS�'A YUHI7'E.Fi�PC.'ECi11L�:1lYA'F�fii1i/4HIC,�OH:fi4iE.BAGIG-E' `:'>.`H.Qt�.AitAN:ANlRi::Ei'[i:•1R�W`WHEN:QFIECKINQ73iE.ENOQR8Eh1ENT3::, ;+��:� � ` B A N K O F A M E R 1 C A`�/ � Cashier's Check t•ro. 1017610454 Robin Brock From: Sent: To: Cc: Greg Hyden <GHyden@nasonyeager.com> Wednesday, February 24, 2021 10:39 AM Robin Brock India Riedel; Marcos Montes De Oca; Christina Curl; Anthony Smith; City Attorney; Carlyn H. Kowalsky; Stacey Janowitz Subject: RE: City of Okeechobee v. Gloria Rodriquez, et al. Attachments: City of Okeechobee v Rodriguez fully executed Settlement Agreement.pdf Dear Robin, Please find the Settlement Agreement attached. I did send it to Opposing Counsel yesterday and asked about the status of the check. I will follow up with Opposing Counsel if I do not hear from him by the end of the day. Thanks! G reg Greg Hyden Attorney at Law � 1��a�n�� er _ � d�th3i?t� 1 i:k'k6:1t15� � tLC�ill�:C), iv�'#, Email: ghyden@nasonyeager.com .^,� acaKrvaL•�� :•r� �,ns� �..�. iv�❑ Tel: 561-982-7114 � Fax: 561-982-7116 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FI , www.nasonyeaqer.com Profile vCard The information contained in this trensmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire transfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to such wire transfer instructions. Think 6reen! Please do not print this e-mail unless absolutely necessary. From: Carlyn H. Kowalsky Sent: Wednesday, February 24, 2021 7:59 AM To: Robin Brock <rbrock@cityofokeechobee.com>; City Attorney <cityattorney@cityofokeechobee.com> Cc: Greg Hyden <GHyden@nasonyeager.com>; India Riedel <iriedel@cityofokeechobee.com>; Marcos Montes De Oca <mmontesdeoca@cityofokeechobee.com>; Christina Curl <ccurl@cityofokeechobee.com>; Anthony Smith <asmith@cityofokeechobee.com> Subject: Re: City of Okeechobee v. Gloria Rodriquez, et al. Thank you Robin Greg from our office will sign and return to the City for your records. Christina - please monitor and let us know when the City receives the check. Carlyn Get Outlook for iOS From: Robin Brock <rbrock@cityofokeechobee.com> Sent: Tuesday, February 23, 2021 3:11 PM To: City Attorney Cc: Greg Hyden; India Riedel; Marcos Montes De Oca Subject: RE: City of Okeechobee v. Gloria Rodriquez, et al. Carlyn, As requested, attache�d is the settlement agreement signed by the Mayor. Robin Brock Executive Assistant �� IC%�@ r'LCSpI�;� ��'_:14�i 55 SE 3�d Avenue Okeechobee, FL 34974 Phone: (863) 763-3372, ext. 9812 Direct: (863) 763-9812 Email: rbrock(c�citvofokE�echobee.com Website: www.citvofoke�chobee.com NOTICE: Under Florida law, email addresses are public records. If you do not want your email address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing, Florida Statute 668.6076. CITY OF OKEECHOBEE ELE=CTRONIC DEVICE DISCLAIMER: Florida has a very broad public records law. Most written communications to or from loc;al officials regarding city business are public records available to the public and media upon request. Your correspondence via e-mail, text message, voice mail, etc., may therefore be subject to public disclosure. From: Carlyn H. Kowalsky <CKowalsky@nasonyea�er.com> Sent: Monday, February 22, 2021 4:20 PM To: Robin Brock <rbrock cityofokeechobee.com> Cc: City Attorney <citvattornev citvofokeechobee.com>; Greg Hyden <GHvden@nasonvea�er.com>; India Riedel <iriedel@cityofokeechobee.com> Subject: FW: City of Okeechobee v. Gloria Rodriquez, et al. Hi Robin - The next time you have the Mayor in to sign documents, would you please have him sign this settlement agreement and then sca�n and return it to us. I believe it was approved on Feb. 16tn Once signed, the City wi91 receive a check. Thanks so much! Carlyn Carlyn H. Kowalsky Attorney at Law Email: CKowalsky@nasonyeaaer.com Tel: 561-982-7114 � Fax: 561-982-7116 Mobile: 561-248-3922 Profile vCard � 1 l��sc�r� 1�� e� � ¢�tk��,U!ti 1 i'tK1,:l� � I-lihll'JiU, 9':t. :��9c��.rtz��:�a .;t��„ _st. i�,��u 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FI www. nasonveaqer.com The information contained in this transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/ortelephone expenses. WIRE fRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire trensfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to such wire transfer instructions. Think Green! Please do not print this e-mail unless absolutely necessary. From: Greg Hyden Sent: Wednesday, February 17, 2021 11:15 AM To: Carlyn H. Kowalsky <CI<owalskv@nasonvea�er.com>; John Fumero <JFumero@nasonyea�er.com> Subject: FW: City of Okeechobee v. Gloria Rodriquez, et al. Since Council approved the settlement, someone from the city needs to sign the settlement agreement. Once they have, I will sign as counsel. G reg This email has been scann2d for email related threats and delivered safely by Mimecast. For more information please visit htcq://vwvw.�nimecast.com This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com 3 TO: VOUCHER CITY OF OKEECHOBEE 55 SE THIRD AVENUE OKEECHOBEE, FL 34974-2903 863-763-3372 Nason Yeager Gerson Harris & Fumero, P.A. 3001 PGA Boulevard, Suite 305 Palm Beach Gardens, FL 33410 ITEM NO ACCT. NUMBER 1 � 01-514-3100 QUANTITY I UNIT DESCRIPTION Attorney Fees ��c2as9is ai9ni� Brantley 12095-26577.Oa1 �sca,�czas9iv ¢�nt� Kemp 12095-26577.003 (stmrrt2459204/9/21) Rodriguez 12095-26577.005 �scmm2as9zi ai9�zi� Cappetta 12095-26577.006 ��c�asva2a�ni� S FL BBQ 12095-27283 C�,�,t zas�zs a�r�r� Walgreens 12095-26577.008 ��c zas9zs a�ni� TOTAL PO Amount $ 56,440.00 2/3/21 Add'1 funds 25,000.00 Reas. � 74,391.33'✓ Bal�nce $ 7,008.G7 ✓ ' � : .�' -� � CITY OF OKEECHOBEE IS EXEMPT FROM FEDERAL EXCISE AND TRANSPORTATION TAXES AND STATE SALES TAX. DO NOT INCLUDE THESE TAXES IN YOUR INVOICE. EXEMPTION CERTIFICATE WILL BE SIGNED UPON REQUEST. SALES TAX EXEMPTION N0. 85-8012621656C-6 FEDERAL I.D. NO. 59-6000393 925.77v 960.96 � 385.00✓ 425.54� 1072.50✓ 1182.50✓ 14352.27 AUTHORI2E SIGNATUR b PO 5016 Draw 8 E ' �! [? r j� r � t, � �. � � ,, ��.' �� { � } � , i; Li ' � ,, 5/4l2021 .. UNIT AMOUNT $9,400.00 PARTIAL( ) FINAL � � RECEIVED PAAY 0 5 202� CITY OF OKEECHOBEE, -vs- PETITIONER, RESPONDENT, Gloria Rodriguez / CODE ENFORCEMENT SPECIAL MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA LIEN / ORDER CASE NO. 18-043 THIS CAUSE came before the Code Enforcement Board, City of Okeechobee, for public hearing on June 25 , 20 19 . After due notice to the respondent, the Board having heard evidence on the alleged violation by witnesses or affidavit makes the following findings: A. FINDINGS OF FACT: Lots: 17 & E I/2 of Lot 16 Blk: 132 Section: City of Okeechobee Parcel: 3-15-37-35-0010-01320-0160 Property location: 914 NW 2" Street, Okeechobee, FL Property owner: Gloria Rodriguez Property has been found to have an unsafe house with roof damage which needs. to be demolished. B. CONCLUSIONS OF LAW: The owner of the property described above has been found in violation of International Property Maintenance Code Ch 3 Sec 304.1.1(8) Unsafe condition and Sec 304.7 Roof damage C. ORDER: The City of Okeechobee Code Enforcement Special Magistrate has determined you violated the International Property Maintenance Code, Ch 3 Sec 304.1.1(8) Unsafe condition and Sec 304.7 Roof damage concerning your property located at 914 NW 2nd Street, Okeechobee, FL . If you do not correct the violation before June 25, 2019 or notify the , a� p Code Enforcement Officer of the correction, the Magistrate imposes a fine of $ 25.00— per day µ.,rr commencing that date and continuing daily until the violation is corrected or the city is notified M =;;_; C.0 Lrj CU 000� Q ;.0 by you and verifies the correction, which ever first occurs. Further, if you do not correct the _r M %n �..�.� violation by said date, a copy of this order as a claim of lien, shall be recorded in the office of o co.�r`e the Clerk of Circuit Court, Okeechobee County, Florida, and once recorded, becomes a lien `; � --a „ on real and to Florida Statute 162. You have a right within thirty -r 1— FJ �rrrr personal property pursuant 3 �M;-. days, to appeal this finding and order by Writ of Certiorari to the Circuit Court, Okeechobee C m M -n — County, Florida. If you correct the violation prior to the above date, it is your obligation to IJ � rO `" t-< rn FJ FJ U1 . . Ili contact the Code Enforcement Officer to verify such compliance. =' rJ � FJ .s µ� .. r- _Q o 7 .0 D T � 3 AGREED AND ORDERED this 31-) day of JGLIti , 2019 . CITY OF OKEECHOBEE, Petitioner Gloria Rodriguez Respondent CODE ENFORCEMENT City of Okeechobee, Florida Magistrate ATTEST: 4 U Recording Secretary STATE OF FLORIDA COUNTY OF OKEECHOBEE PERSONALLY appeared before me the undersigned authority, Roger Azcona , Fred Sterling and Sue Christopher , well known to me and known by me to be the Code Enforcement Special Magistrate, Code Enforcement Officer and Recording Secretary, respectively, of the CITY OF OKEECHOBEE CODE ENFORCEMENT. SWORN TO AND SUBSCRIBED before me this 3rd day of 201 q. pattq N. 6'ar'tft' , NOTARY P BLIC My Commission expires: ao�Y% Pus, Notary Public State of Florida Patty M Burnette < t+< My Commission GG 008157 'Ror pd• Expires 1010212020 Please return to: City of Okeechobee Code Enforcement 55 SE 3' Avenue Okeechobee, FL 34974 (863) 357-1971 Case #18-043, Gloria Rodriguez Date Event/Document December 3, 2020 Case 18-043 Gloria Rodriguez was approved by the City Council for Foreclosure 2019 — Fine started June 25, 2019 @$25.00 per day, property is still in noncompliance. Amount Due thru 09/25/2019 thru 09/30/2020 =$11,575.00 February 1, 2021 Received Settlement Proposal in the amount of $5,000.00 February 4, 2021 Conference call with City Attorney Carlyn Kowalsky, C/O Smith, Major Hagan, Lt Bernst and C/O Curl ref to the Settlement Proposal that was received. City Attorney will present a counteroffer for half of the fine plus attorney fees totaling $9,616.74. February 5, 20.21 Received drafted letter from City attorney Kowalsky to review for counteroffer of'/z of the lien amount plus attorney fees and coast expended totaling $11,355.74. Counterofferwas approved by Code Enforcement, Major and Chief. Copy of letter placed in file. February 8, 2021 Received email from City Attorney Greg who advised that the property owner accepted the counteroffer and asked how we would like to receive the funds. Replied to email on February 9, 2021 advising that the funds could be sent in a cashier's check made payable to the City per Major Hagan. February 8, 20;21 Received email from City Attorney Kowalsky asking that the back up memo be confirmed and forward to Robin to be added to the City Council Meeting agenda for 2/16/21. February 9, 2021 Backup memo was confirmed, printed on letter head and initialed by the Chief and forwarded to Robin requesting the case be added to the agenda. Received confirmation from Robin that the case would be added to the agenda for the City Council meeting on 2/16/21. February 24, 2021 Settlement payment (Cashier's Check) for $11,355.74 and the receipt. March 24,2021 Release of Lien recorded at Clerk of the Circuit Court and Comptroller. CASE CLOSED Case #18-043, Gloria Rodriguez Date Event/Document April 12, 2018 Properly was found to have violations and a courtesy card was sent out, Damaged Building — Contact Building Department October 23, 2C118 A Notice of Violation was sent out regarding the property in violation International Property Maintenance Code Chapter 3 Section 304.7 Structure Unsafe Due to Roofing Defects and Inadequate Drainage January 18, 2019 A Notice of Violation and Notice of Hearing was sent out Certified Return Receipt Mail and was returned signed for by N. Rodriguez 01/22/2019 April 9, 2019 Case 18-043 was brought in front of the Special Magistrate and was postponed until the next regular scheduled Hearing. Mrs. Rodriguez's brother stated that he was getting with Apex Septic to pump and fill in the septic tank, and then get the demolition done. May 14, 2019 the owner's brother was given a 30-day extension to have the septic tank filled in, power shut off, personal items removed and obtain a demolish permit. Mr. Rodriguez was given a 30-day extension to get the power turned off and the water, remove any personal belongings and obtain a demo permit. Special Magistrate stated that if not done within the next 30 days a fine of $25.00 per day is to be imposed. June 2019 A letter of Special Magistrate Hearing was being rescheduled from June 11, 2019 to June 25, 2019. June 25, 2019 Lien Order was filed at the Okeechobee Court House, Violation of IMPC Chapter 3 Section 304.1.1() Unsafe Conditions and Section 304.7 Roof Damage. A$25.00 per day fine was started June 25, 2019 October 17, 2019 A letter of fines having accrued over 90 days, and could result in foreclosure October 17, 2019 A Statement of Violation and Notice of Hearing was sent out Certified Return Receipt mail for Recommendation of Foreclosure for the November 12, 2019 Hearing October 23, 2019 The property was posted due to not receiving a signed green card for the SOV & NOH November 12, Special Magistrate Azcona recommended that Case 18-043 be sent to the 2020 next City Council Hearing for foreclosure approval Jerald D Bryant Clerk of the Circuit Court & Comptroiier OKEECHOBEE COUNTY 312 NW 3rd Street Okeechobee, FL 34972 Transaction # 2019094636 Receipt # 2021002575 Print Date: 3/24/2021 2:d5:12PM Cashier Date: March 24, 2021 Client: CITY OF OKEEc:HOBEE 1 Item RELEASE Instrument Number: 2021003587 RECORDING FEES BOCC FACC FEE TRUST FUND FEE COURT RELATED PRMT CASH AMOUNT: $10.00 CHANGE: $0.00 Total Payments Total Fees Shortage Check Overage Rec By: Madalyn Pinon Deputy Clerk 5.00 2.00 0.10 1.00 1.90 $10.00 $10.00 $0.00 $0.00 www.clerk.co.okeechobee.fl.us/Official Records.htm 6�y " �y , � � � � � � � �.�. Smith Rodric�ucZ �r�E✓l �I� From: Sent: To: Cc: Subject: JJ, Christina Curl Monday, March 15, 2021 3:41 PM J.J. Smith Anthony Smith; Bobbie Jenkins RE: Pending Updates 1.-Leon & Tisha Edouard-still making payments. They have 7.5 more payments to go. 2.-Manuela Pineda- we received full payment on 3/9/21. Satisfaction of Lien has been drawn up awaiting Magistrate's signature. Once we have the Satisfaction recorded, we will bring the file to you. 3.-Fortex Holdings- sti�l awaiting payment, they have till April 19, 2021 to make payment if not received file will be tur�ed over to the lawyers for foreclosure. 4.- Gloria Rodriguez- waiting for the Release of lien from the lawyers once I have that I will bring the file to you. If you have any more questions, give us a call. Thank you! Christina Curl City of Okeechobee Assistant Code Enforcement Officer 50 SE 2"d AVe. Okeechobee, FL. 34974 Phone (863)763-2626 Extension 9802 Fax (863) 763-7804 �� -' -� NOTICE: Florida has a very broad public records law. As a result, any written communication created or received by the City of Okeechobee officials and employees will be available to the public and media, upon request, unless otherwise exempt. Under Florida law, e-mail addresses are public records. If you do not want your e-mail address released in response to a public records request, do not send electronic mail to this office. Instead, contact our office by phone or in writing. From: J.J. Smith <jsmith@cityofokeechobee.com> Sent: Monday, March 15, 2�21 2:42 PM To: Christina Curl <ccurl@cityofokeechobee.com> Cc: Anthony Smith <asmith@cityofokeechobee.com>; Bobbie Jenkins <bjenkins@cityofokeechobee.com> Subject: Pending Updates Christina, I am updating the status on some of our pending items. When you have a moment, can you please check on this stuff for me and let me know if anything has changed: 1) Leon & Tisha Edouard: Case #190626010 — Last we spoke, they were still making payments. 2) Manuel(a?) Pineda: 1124 SW 8th St (Case # is wonkv on our end for this one) — Last we spoke, you had sent the letter about the reduction and were awaiting payment. 3) Fortex Holdin�s: Case #190718010 - Last we spoke, you had sent the letter about the reduction and were awaiting payment. 4) Gloria Rodri�uez: Case #18-043 (Court #472020CC000190CCAXMXI— Our office has received the completed settlement paperwork for this case. As long as there wasn't anything additional pending, you can bring your file over or I can grab it from you and our office will merge the files and keep. Thanks! J.J. Smith Administrative Secretary City Clerk's Office City of Okeechobee 55 SE 3'd Avenue Okeechobee, FL 34974 Phone: (863) 763-3372 ext: 9815 Direct: (863) 763-9815 Fax: (863) 763-1686 _� l,(?F fJNF,.:� ��• �^ �'f� kJ ��y� ��'YyYy NOTICE: Florida has a very broad public records law. As a result, any written communication created or received by the City of Okeechobee officials and employees will be available to the public and media, upon request, unless otherwise exempt. Under Florida law, e-mail addresses are public records. If you do not want your e- mail address released in response to a public records request, do not send electronic mail to this office. Instead, contact our office by phone or in writing. �� N° SQ�� RECENED from � �.. CITY OF OKEECHOBEE, FLORIDA � 55 S.E. 3rd Avenue, Okeechobee, FL 34974 (863)763-3312 -� e� � `�t 20�_ �� o �.�� :�-�.�Z, � � `e J�� -�-ro�� -�-�.t � �-.,,c�ace,b � ++�� Dollars �oo � o � �:'`tles C ase, � L1.`?o7p`�o�GC�Co'l`�(�GG�-iX�k � �` _ r� : �, l ; 3��. `Z �-( c�, CLERK '.--c>�.;;>:: ��. �:�� fc7; : w � `� City of Okeechobee Code Enforcement 50 SE 2"d Street Okeechobee, Florida 34974 (863)763-9795 To: From: Subject: Date: City Council Members Robert Peterson, Chief of Police C;arlyn Kowalsky, Assistant City Attorney 1; , � Gonsider settlement proposal in the case of City of Okeechobee, Florida v. Gloria Rodriguez, et. al., Case Number: 47 2020 CC 000 190 CC AX MX February 7, 2021 The City filed this case to foreclose on a code enforcement lien on November 2, 2020. The buildings causing the code violations have now been demolished and the property is now in compliance. The property owner has ofFered to settle the case and pay $11,355.74, to be paid on or before February 26, 2021. This amount covers all of the City's attorney's fees and costs plus one half of the lien amount. Staff recomme�nds acceptance of this settlement offer. R. GREGORY HYDEN E-MAIL ADDRESS: ghyden�nasonyeager. com February 4, 2021 VIA EMAIL: colin@CCameronLaw.com Colin M. Cameron, Esq., P.A. Attn: Colin M. Cameron, Esq. 200 NE 4t" Ave. Okeechobee, FL 34972-2981 re: City of Okeechobee v. Gloria Rodriguez et. al. Case No.: 47 2020 CC 000190 CC AXMX Dear Colin, DIRECT DIAL: (561) 471-3524 FAX NUMBER: (561) 982-7116 As you are aware, this firm represents the City of Okeechobee ("Okeechobee") in the above noted matter. VVe provided you with a template of a settlement agreement on January 29, 2021 but have not received any further communications from you. We have spokeri with City staff regarding your client's offer of $5,000.00 to resolve the case. City staff are unlikely to recommend City Council approve that. However, City Staff is willing to recommend approval of payment of '/2 of the lien amount plus attorney's fees and costs expended. The fines began accruing on June 25, 2019 and had a daily fine of $25.00. Thus, half of the amount as of th� date of this letter is $7,362.50. The attorney's fees and costs of $3,993.25. Thus, the total a�mount would be $11,355.74. Please let me know your clients' response at your earliest possible convenience. Thank you for your time and consideration in this matter. Many Thanks, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. R. Gregory Hyden `aBlf��lY.LI Okeechobee County Property Appr Okeechobee Cour.ity Property Appraiser 2020 Certified Values liickev L. liaradi, t;F:1 updated: 1/28/2021 i Parcel: « 3-15-37-3�-0010-01320-0160 (33878) » Aerial viewer Pictometery Google Maps Owner 8 Property Infn Res�it:52ofi5� ?'2020 2019 2oia 20�� 2015 saies _ . .-�.�---�- T- _ - � _ . ,� �: � 'RODRIGU�Z GLORIA �r.-- � , �• ...^� RODRIGUEZ NOE -� r� , Owner C/O NOE RODRIQUEZ . � - 17324 NW 213TH DR � - � �'"''�" '.��'`" �*; �"��'� HIGH SPRINGS, FL 32643-6403 � :,� "� ' �k �•'` # ' - _.. __--__. . .. � L — A�!, i. '� _' M �' ' � . . CITY OF OKEECHOBEE LOT 17 & E 1/2 OF LOT 16 � ' � } Site 914 NW 2�kD ST, OKEECHOBEE �, • y „' ; i�� a - -- — ------ ,- { . £�_. -- - -- -- � ��11��,� � •� � _� Description- � u�� Y+,�i _ E � �4, ��,- ,_ ",� "3 r? � , BLOCK 132 � ' ^"h�' �j+�� -- --. _ __ -- _ _ , — ' ; �. . ---- -- 't 4 3^. � ve, '�' I . Area 0.258 AC ( S/T/R 15 37-35 �, " � . tp. . ..�`' �" � ; y�y_ �:;.- � rn l� TM� The Descn tion above is not to oe us d 01t00`elTax District I50 ,� i/�"i1� ,3�r, f _ Use Code" SINGLE FA ) 7 � � �•� .� - p gai Description for this parcel �� 1��, ^� �� I in any legal transacUon. `�,. F,�.� ,_ ,� � '�'� "The Use Code is a Dept. of Revenue code. Please contact Okeechobee County '� - �,,;::t �' . , Planning 8 Development at 863-763-5548 for zoning mfo. � � ; _.._ " •'�i . ""`-•+; • � � � ---- -- -- — !,. ,_ „ ' , '�— -- --- _ �"r��, _ - ---- - -_ ___ � �� , t ,.� w -- ' Property 8� Assessment Values = i ,; — q '�„ � �-. Y.�; � �� ,, �� 2019 Certified Values 2020 Certified Values . �� - — - --- --- , Mkt Land � $7,500 Mkt Land I $7,500 ��; ,_ e.• _, - - • '•• � Ag Land � $0 Ag Land � $0 . ,f."� � t'� � �'� i��-� --- — .'4 - -- Building $9,134 Building $10,066 ��''$�.�`��a�'T '+ "'` �� 9� ,,=�� ''� � . +Y �" �'}I �,,, -ry , XFOB $1,883 XFOB $1,882 `-'`•... ' ,� �� , ,� �� . �,' ,�,� � ��3 �;�. 's � � =, � :, �'.�� Just $18,517 Just $19,448 � • '� .. � ... � � j �` .. � �� Class - --$0 Class -- --- . �,� ; � f� .,�_. _,� ! Appraised , $18,517 Appraised $19,448 ,�,T, ��; � •�' � ��` s ��,� �.' :� �, . � � �, � � ,;..._ .,,_ � a _ , . rc. � �Z. , . ' SOH Cap [?] $0 SOH/10% � .r.r - K 1 �� a..A.�+ — Cap ('] , � .. � �. _ i � �� ; ^u1 �: Assessed $1�,517 ----- � ,r _ . �+; � , a �1 , -- Assessed I, $19,448 �. Exempt $� -- -' � ..: '}? ,, - � �� i- -- --- -- ----- county:$17,488 Exempt_ _ $p �; .ir �' ' - . y r ''�. Total city:$17,488 county:$19,237 -I„ � � -- •a � j�� Taxable other:$17,488 Total ��ty:$19,237 �, ^� � �:�•� :� `��i:��---- ' s�nooi:$18,517 Taxable ocner:$19,237 i �+ "`� ** scnooe$19,448 � '' '�' Note: Property ownership changes can cause the Assessed value of the property to reset to full Market ✓alue, which could result in higher property ( taxes. � --- — - - .. . _. �' Sales History Sale Date �� Sale Price Book/Page , Deed V/I Qualification �Codes) RCode i - — - 7/18/2011 $100 0703/1044 , WD I U 11 I 11l1/1969 $8,500 0116/0977 i N/A I Q � � + Building Characteristics Bldg Sketch Description* Year Blt Base SF Actual SF Bldg Value -- Y— --- , , --- -- - - __-- -- - --- ' Sketch � SF SNGLFAM (0100) 1936 I 1436 ' 1500 ' $10,066 - _- - - - - _ _._._ — "Bldg Desc determinations are used by the Property Appraisers office solely for the purpose of determining a property's Just Value for ad valorem tax purposes and should not be used for any other purpose. _ _ _ _ -- _ —,, � Extra Features � Out Buildings {Codes) ---- --- -- Code _' Descri tion� Year Blt , Value Units Dims � Condition % Good ' --- - ------- p - ---�— - � � ) AFA W4 MTL FLR MTL 1997 ; $1,882.00 I 160.00 �� 16 x 10 � PD (75%) � � Land Breakdown www.okeechobeepa.com/gis/ 1/2 2/3/2021 Okeechobee County Property Appr � Code ; Description � _ Units i, Adjustmer• � ------�: � _� _ , _. I' 161CI6 � CITY LT (MKT) ; 75.000 FF (0.258 AC) � 1.0000/1.0000 1.0000/ / Eff Rate f Land Value $100 /FF � $7,500 Search Result: 52 of 157 I OO Okeechobee County Property Appraiser I Mickey L. Bandi, CFA I Okeechobee, Florida I 863-763-4422 by: GrizzlyLogic.com www.okeechobeepa.com/gis/ 2�2 To: City Council Members From: Robert Peterson, Chief of Police Carlyn Kowalsky, Assistant City Attorney Subject: Settlement Proposal in the case of City of Okeechobee, Florida v. Gloria Rodriauez, et. al., Case Number: 47 2020 CC 000 190 CC AX MX Date: February 1, 2021 The City filed this case to foreclose on a code enforcement lien on November 2, 2020. The buildings causing the code violations have now been demolished at a cost of $2,400.00 to the homeowner(s) and the property is now in compliance. The City has a lien of $11,57�� on the property and has expended $3,829.24 in attorneys' fees in this matter. Therefore, a total of $15,404.24 is due to the City from the property owner. The owner has offered to pay $5,000 to settle the case and remove the lien. Staff does not recommend acceptance of this settlement offer. � f (� p� � 00 � 12/17/2020 Rodriguez prope�rty. Mail - Fred Sterling - Outlool Fred Sterling <fstE�rling@cityofokeechobee.com> Thu 12/ i 7/2020 1 Q:53 AM To: Greg Hyden <GHyden@nasonyeager.com> G reg, Sorry, I left out that the offer has to go before City Council for approval. It will go before the Special Magistrate on the 12th of January since he has to forward it to the City Council for their approval. Fred https://outlook.office365.com/mail/sentitems/id/AAQkADZIZGU0MTg2LTMOMGQtN Dk3Mi04Mjc2LTg 1 Zj IwN mE4ZmEwMAAQAJOyFWxexKN BoYfyYQ... 1/1 12/17/2020 Re: Rodriguez prope�rty Fred Sterling <fsterling@cityofokeechobee.com> Thu 12/17/2020 9:57 AM To: Greg Hyden <GHyden@nasonyeager.com> Greg, This is the offer from the City. Mail - Fred Sterling - Outloo'� A fine of $25.00 was levied on the property from 06/25/2019 and ran to 11/12/2020. That is 477 days @$25.��0 = 11,925. The City will accept 10% plus your fees. Let me know what they say. Thanks, Fred From: Greg Hyden <GHyda�n@nasonyeager.com> Sent: Wednesday, December 16, 2020 3:00 PM To: Fred Sterling <fsterling@cityofokeechobee.com> Cc: Robert Peterson <rpeterson@cityofokeechobee.com>; John Fumero <JFumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz <SJanowitz@nasonyeager.com>; Donald Hagan <dhagan@cityofokeechobee.com> Subject: RE: Rodriguez praperty Dear Mr. Steriing, I just wanted to follow up on the below email. Please let me know either way. Thanks, Greg Greg Hyden Attorney at Law Email: ghydenCa�nasonyeager.com Tel: 561-982-7114 � Fax: 561-982-7116 Profile vCard N�sa�Yea �r ��t:�un ��s � Fur,��xc,, �y:�.� A1 3�3N.N1'is .-., _?.45 _sl. t7i�U 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FL � 33487 www.nasonyeager.com The information contained in this transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are liereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to tlie increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire transfer instructions, please tall Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to such wire transfer instrudions. Think Green! Please do not print this e-mail unless absolutely necessary. From: Greg Hyden Sent: Monday, December 7, 2020 11:59 AM To:'Fred Sterling' <fsterlin�;@cityofokeechobee.com> https://outlook.office365.com/mail/i n box/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3M iO4Mjc2LTg 1 ZIwNmE4ZmEwMAAQALjJrqeQWEZvikkzmA41f7Y... 1/2 12/17/2020 � Mail - Fred Sterling - Outlook Cc:'Robert Peterson' <rpeterson@city ,�eechobee.com>;1ohn Fumero <jfumero@naso�iy�uger.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz (SJanowitz@nasonyeager.com) <Slanowitz@nasonyeager.com> Subject: RE: Rodriguez property Dear Mr. Sterling, Did the City enter into same agreement with the home owners to settle the matter for $3,500? I need to know because I would need to dismiss the Circuit Case and likely have the unit owners sign a settlement agreement. Please let me know asap. Thanks! Greg From: Greg Hyden Sent: Thursday, December 3, 2020 2:24 PM To: Fred Sterling <fsterling@cityofokeechobee.com> Cc:'Robert Peterson' <rpeterson@cityofokeechobee.com>; John Fumero <jfumero@nasonyeager.com>; Carlyn H. Kowalsky <CI<owalsky_@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz (SJanowitz@nasonyeager.com) <SJanowitz@nasonyeager.com> Subject: Rodriguez property Dear Fred, Per your request, the attorney's fees and costs are $3,438.19. However, some work will be involved in dismissing the case etc. So I would assume that the total will be around $4,000 or less. Tha n ks, Greg This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com https://outlook.office365.com/mail/inbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg 1 ZIwNmE4ZmEwMAAQALjJrqeQW EZvikkzmA41f7Y... 2/2 12/17/2020 RE: Rodriguez property Greg Hyden <GHyderi@nasonyeager.com> Wed 12/16/2020 3:00 PM Mail - Fred Sterling - Outloo'• To: Fred Sterling <fsterling@cityofokeechobee.com> Cc: Robert Peterson <rpeterson@cityofokeechobee.com>; John Fumero <JFumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz <Slanowitz@nasonyeager.com>; Donald Hagan <dhagan@cityofokeechobee.com> Dear Mr. Sterling, I just wanted to follow up on the below email. Please let me know either way. Thanks, Greg Greg Hyden � , 1 Vc�� I�'.C�, �:� Attorney at Law �tti.sun r��s s� rur.�i�:�, ��;�. Email: ghyden nasonyeager.com � :,� ��uv,:rs ;�a "�s�. ::.�. i:��,u Tel: 561-982-7114 � Fax: 561-982-7116 � 750 Park of Commerce Bivd., Suite 210 �Boca Raton �FL �33487 www.nasonyeager.com Profile vCard The information contained in this tr3nsmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are liereby notified that any dissemination, distribution or copyiny of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE PRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire transfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to such wire transfer instructions. Think Green! Please do not print this e-mail unless absolutely necessary. From: Greg Hyden Sent: Monday, December ', 2020 11:59 AM To:'Fred Sterling' <fsterlin�;@cityofokeechobee.com> Cc: 'Robert Peterson' <rpeterson@cityofokeechobee.com>; John Fumero <jfumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz (SJanowitz@nasonyeager.com) <SJanowitz@nasonyeager.com> Subject: RE: Rodriguez property Dear Mr. Sterling, Did the City enter into some agreement with the home owners to settle the matter for $3,500? I need to know because I would need to dismiss the Circuit Case and likely have the unit owners sign a settlement agreement. Please let me know asap. Thanks! Greg https://outlook.office365.com/mail/inl�ox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg 1 ZIwN m E4ZmEwMAAQALjJrqeQW EZvikkzmA41f7Y... 1/2 12/17/2020 • Mail - Fred Sterling - Outlook From: Greg Hyden Sent: Thursday, December 3, 2020 2:24 PM To: Fred Sterling <fsterling�cityofokeechobee.com> Cc:'Robert Peterson' <rpeterson@cityofokeechobee.com>; John Fumero <jfumero nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz (SJanowitz@nasonyeager.com) <SJanowitzCa)nasonyeager.com> Subject: Rodriguez property Dear Fred, Per your request, the attorney's fees and costs are $3,438.19. However, some work will be involved in dismissing the case etc. So I would assume that the total will be around $4,000 or less. Thanks, Greg This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com https://outlook.office365.com/mail/inbox/id/AAQkADZIZG UOMTg2LTMOMGQtNDk3M iO4Mjc2 LTg1 Z IwN mE4Zm EwMAAQALjJrqeQW EZvikkzmA4lf/Y. .. 2/2 12/4/2020 Rodriguez property Mail - Fred Sterling - Outlook Greg Hyden <GHyden@nasonyeager.com> Thii "12/3/2020 2:2n PM To: Fred Sterling <fsterling@cityofokeechobee.com> Cc: Robert Peterson <rpeterson@cityofokeechobee.com>; John Fumero <JFumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz <SJanowitz@nasonyeager.com> Dear Fred, Per your request, the attorney's fees and costs are $3,438.19. However, some work will be involved in dismissing the case etc. So I would assume that the total will be around $4,000 or less. Thanks, Greg Greg Hyden � °� i Vt��n'��C� �r Attorney at Law _ i (;Et�Sl1t\ IL'1ht:ly & h�GhlE1tU, i'..;�. Email: ghydenC�nasonyee�ger.com �,� ,�:��„y,,�s :,.;. �;�,�s _,,,. ;,�;�� Tel: 561-982-7114 � Fax: 561-982-7116 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FL � 33487 www.nasonyeag�r.com Profile vCard �� The information contained in this transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire trensfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the informatlon contained within said wire transfer instructions prior to sending funds pursuant to :>uch wire transfer instructions. Think Green! Please do not print tFiis e-mail unless absolutely necessary. _ _ _ _ _ _ _ __ _ _ _ _ This email has been scanried for email related threats and delivered safely by Mimecast. For more information please visit http:/lwww.mimecast.com https://outlook.office365.com/mail/inbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3M iO4Mjc2LTg1 Zj IwN m E4ZmEwMAAQALjJrqeQWEZvikkzmA41f7Y... 1!1 12/4/2020 Rodriguez property Mail - Fred Sterling - OutlooF Greg Hyden <GHyden@nasonyeager.com> Thu 12/3/2020 224 PM To: Fred Sterling <fsterlingC>cityofokeechobee.com> Cc: Robert Peterson <rpeterson@cityofokeechobee.com>; John Fumero <JFumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; StaceyJanowitz <SJanowitz@nasonyeager.com> Dear Fred, Per your request, the attorney's fees and costs are $3,438.19. However, some work will be involved in dismissing the case etc. So I would assume that the total will be around $4,000 or less. Thanks, Greg Greg Fiyden ? �,� ��on�'+�a �r Attorney at Law � � d_:L:�S4,�f\ Ii1t�KIS & hLlh11h�1, 1'.:1. Email: ghydenCalnasonye��.ger.com y :�i ��,ouN,.ss �,.� _:r;�. �� __.. :�:�+�u Tel: 561-982-7114 � Fax: 561-982-7116 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FL � 33487 i www.nasony_�ager.com Profile vCard i The information contained in this transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telc�phone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire transfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to ��uch wire transfer instructions. Think Green! Please do not print tY�is e-mail unless absolutely necessary. . . ... __ .. . .. .. . _. . . _ _ . . .. . . . .. ... . . . . . . .. .. . ... .._.. ..... ......_ _.... _. .. .. ... ..... ...._ .._. ..... This email has been scanned for email related threats and delivered safely by Mimecast. For more information pleas;e visit http:Nwww.mimecast.com __ _._ _ __ https://outlook.office365.com/mail/in��ox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1 ZIwNmE4ZmEwMAAQALjJrqeQWEZvikkzmA41f7Y... 1 /1 11 /24/2020 Mail - Fred Sterling - Outloo{ FW: City of Okeechobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Greg Hyden <GHyder�@nasonyeager.com> Tue 11/24j2020 3:40 PM To: Robert Peterson <rpeterson@cityofokeechobee.com>; Fred Sterling <fsterling@cityofokeechobee.com> Cc: John Fumero <JFumeroC�nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz <SJanowitz@nasonyeager.com> Just a FYI on the Rodriguez property. Greg From: Colin Cameron [mailto:colin@ccameronlaw.comj Sent: Tuesday, November 24, 2020 3:19 PM To: Greg Hyden <GHyden(�nasonyeager.com> Cc:'Linda Wilson' <linda2@ccameronlaw.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Stacey Janowitz <SJanowitz@nasonyeager.com>; John Fumero <1Fumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com> Subject: RE: City of Okeechobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Greg (2"d response) TIMELINE: Permit has been pulled. Contractor says he will have the buildings removed by the end of November, 2020 — i.e., within 6 days.... I have the Reduction requ��st form in hand, signed by Raul Rodriguez, and ready to file with the City when the buildings are removed and Fred Stirling (the Code Enforcement Officer) confirms removal, and that the property is in compliance. Incidentally, Fred Stirling has been a client of this office. We did a will for him and Jan (his wife) a few years ago. Okeechobee is a small town. - Colin Colin M. Cameron, Esq. Colin M. Cameron, Esq., P.A. 200 NE 4th Ave. Okeechobee, FL 34972-2981 Telephone (863) 763-860C colin CCameronlaw.com linda2 CCameronLaw.corn From: Greg Hyden <GHyden nasonyeager.com> Sent: Monday, November 23, 2020 2:45 PM To: colin ccameronlaw.cam Cc:'Linda Wilson' <linda2 �ccameronlaw.com>; Missy Hernandez <mhernandezC�nasonyeager.com>; Stacey Janowitz <SJanowitz(a�nasonyeager.com>; John Fumero <JFumero(n�nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky�nasonyeager.com> Subject: RE: City of Okeecl�obee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Dear Colin, Thanks! You will need to file an Acceptance of Service and/or a Waiver of Service. Once yau get that done and send me the proposed timeline for the remediation of the property, I will get to work on an agreed order. Greg From: Bill Cameron [mailto:bill(a�ccameronlaw.com] Sent: Monday, November 23, 2020 12:42 PM To: Greg Hyden <GHyden �?nasonyeager.com> Cc:'Linda Wilson' <linda2(�ccameronlaw.com>; Missy Hernandez <mhernandezC�nasonyeager.com>; StaceyJanowitz <SJanowitz@nasonyeager.com>; John Fumero <1FumeroC�nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky�a nasonyeager.com> Subject: RE: City of Okeechobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Greg: Yes, I have been authorized to accept service for Raul Rodriguez, and he says he has POA for Gloria (I have not seen it, but accept his word), and he okays me accepting service for her - if we get an extension of time to file an Answer (no motions) for all three, until https://outlook.office365.com/mail/inbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1ZiwNmE4ZmEwMAAQAEhgaIK1 h00biwsUnjpuMqU... 1/4 11 /24/2020 lanuary 31, 2021. Please advise. - Colin Colin M. Cameron, Esq. Colin M. Cameron, Esq., P.A. 200 NE 4th Ave. Okeechobee, FL 34972-2981 Telephone (863) 763-860CI colin CCameronLaw.com. linda2 CCameronLaw.com Mail - Fred Sterling - Outloo{ From: Greg Hyden <GFiyde�nasonyeager.com> Sent: Friday, November 20, 2020 3:00 PM To: Bill Cameron <bill(a�ccameronlaw.com> Cc: 'Linda Wilson' <linda2 �ccameronlaw.com>; Missy Hernandez <mhernandezC�nasonyeager.com>; Stacey Janowitz <SJanowitz a nasonyeager.com>; John Fumero <JFumeroC�nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky�nasonyeager.com> Subject: RE: City of Okeecl�obee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Dear Mc Cameron, Thank you for the email. "ou are correct in terms of service. Will you accept service on their behalf? If Ms. Rodriguez is in a nursing home, I'd rather not have to disrupt her with service of process. If so, I am sure we can agree on an extension of time. If not, it is hard for me to agree to an extension of time on parties that have not been served yet as I cannot bind them to a deadline to file an Answer. Let me know. G reg From: Bill Cameron [mailto:bill(�ccameronlaw.com] Sent: Friday, November 20, 2020 2:42 PM To: Greg Hyden <GHyden ��nasonyeager.com> Cc: 'Linda Wilson' <linda2 ��ccameronlaw.com>; Missy Hernandez <mhernandez(a�nasonyeager.com>; Stacey Janowitz <SJanowitzC�nasonyeager.com>; John Fumero <JFumero(a�nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky�a nasonyeager.com> Subject: RE: City of Okeechobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Mr. Hyden: Looking at the Clerk's docN:et sheet online, it appears you have service only on Noe, thus far. His response is due on 11/24/20 (next Tuesday). Raul lives hereiri Okeechobee and has not been served yet. Gloria is, I understand, presently in a nursing home. We expect the demolition to be completed before the end of this month possibly. Client has spoken to the City Code Officer about mitigation, and they expect to have it before the Code Board or City Commission for reduction shortly after completion. Can we have an extension� of time, until end of January, 2021, in which to file an Answer on behalf of all defendants, if not resolved before then? I could file a response to the discovery requests at the same time, if necessary. Please review with your client and advise. - Colin Colin M. Cameron, Esq. Colin M. Cameron, Esq., P.,4. 200 NE 4th Ave. Okeechobee, FL 34972-29�31 Telephone (863) 763-8600 colin CCameronLaw.com linda2 CCameronLaw.corn https://outlook.office365.com/mail/inbox/idJAAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1ZIwNmE4ZmEwMAAQAEhgaIK1 h00biwsUnjpuMqU... 2/4 11 /24/2020 Mail - Fred Sterling - OutlooF From: Greg Hyden <GHyden nasonyeager.com> Sent: Friday, November 13, 2020 2:15 PM To: Bill Cameron <billCa�cc�meronlaw.com> Cc: Linda Wilson <linda2 c)ccameronlaw.com>; Missy Hernandez <mhernandezC�nasonyeager.com>; Stacey Janowitz <SJanowitzC�nasonyeager.com>; John Fumero <JFumero@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky�nasonyeager.com> Subject: RE: City of Okeechobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Dear Colin, Please let me know when the demolition is complete. Once that is done, the property owner can fill out a fine reduction request form, which is available from the City Code Enforcement office. Then we can present it to Council for consideration. Thanks! Greg Greg Hyden � Attorney at Law I �� `a �r , _ _ Email: ghydenCa�nasonyea,ger.com � � '��-��" ��'�'�''�� Fi.lhl�hU i'.:'�. ,� �htaelNhlm't'Sr3.3 ._�4.4G -G �9c�tl Tel: 561-982-7114 � Fax: 561-982-7116 750 Park of Commerce Blvd., Suite 210 � Boca Raton � FL � 33487 www.nasonyeager.com Profile vCard The information contained in [his transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal5ervice. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire Yransfer instructions, please call Naso� Yeager using previously known contact informaHon and NOT informatlon provided in the email, to verify the information contained within said wire trensfer instructions prior to sending funds pursuant to such wire transfer instrucHons. Think Green! Please do not print this e-mail unless absolutely necessary. From: Greg Hyden Sent: Friday, November 13, 2020 12:51 PM To:'Bill Cameron' <bi1lCa�ccameronlaw.com> Cc: Linda Wilson <linda2 .ccameronlaw.com>; Missy Hernandez <mhernandez(a)nasonyeager.com>; Stacey Janowitz (SJanowitzla�nasonyeager.c:om) <SJanowitz(a�nasonyeager.com>; John Fumero <jfumero nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky� nasonyeager•.com> Subject: RE: City of OkeecFiobee v Rodriguez, Case No. 2020-CC-190, Okeechobee County Court Dear Colin, i will forward your settlem �nt offer to my client now. As soon as I have a substantive response from my client, i will let you know. Yes, a County Court can pr��ceed with a foreclosure. In my experience, most condominium lien foreclosures remain in County Court due to the jurisdictionai monetary limits for example. A municipal code enforcement lien foreclosure isn't like a tax deed sale where a new chain of title is create��. Rather, a new purchaser takes title with the existing liens (assuming there are superior liens) still attached to the property. In other words, the title may still be clouded. Thanks, Greg From: Bill Cameron [mailto:bill@ccameronlaw.com] Sent: Friday, November 13; 2020 11:25 AM https://outlook.office365.com/mail/inbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1ZIwNmE4ZmEwMAAQAEhgaIK1 h00biwsUnjpuMqU... 3!4 11124/2020 Mail - Fred Sterling - Outlool To: Greg Hyden <GHyden@nasonyeager.com> Cc: Linda Wilson <linda2 c�ccameronlaw.com> Subject: City of Okeechobee v Rodriguez, Case No. 2020-CG190, Okeechobee County Court Mr. Hyden: Please see attached settlement proposal for the above case. Please review with your client and advise. Curiosity question: I known jurisdictional limits are what they are, but, Fla. Stat. §26.012(2)(g) says circuit courts have "exclusive original jurisdiction" over "all actions involving the title and boundaries of real property." Emphasis added. Your law suit seeks to foreclose a CEB lien and "t:hat the property be sold at auction to satisfy the City's claim". Doesn't that necessarily involve title to real property? Can the County Court order a sale of the property without involving the title to the property? - Colin Colin M. Cameron, Esq. Colin M. Cameron, Esq., P.A. 200 NE 4th Ave. Okeechobee, FL 34972-2981 Telephone (863) 763-860G colin CCameronLaw.com linda2 CCameronLaw.corn _ _ _ __ . ___ _ _ _. This email has been scanried for email related threats and delivered safely by Mimecast. For more information plea:>e visit http://www.mimecast.com This email has been scanr?�ed for email related threats and delivered safely by Mimecast. For more information plea:;e visit http://www.mimecast.com This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com https://outlook.office365.com/mail/inbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1ZIwNmE4ZmEwMAAQAEhgaIK1 h00biwsUnjpuMqU... 4/4 11 /19/2020 Mail - Fred Sterling - Outlook FW: [0:57] Message for MB 3bus from a caller at (863) 763-9795 Greg Hyden <GHyden@nasonyeager.com> Thu 11/19/2020 1Z:11 PM To: Fred Sterling <fsterlingC>cityofokeechobee.com> Cc: Stacey Janowitz <SJanowitz@nasonyeager.com>; Missy Hernandez <mhernandez@nasonyeager.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com>; John Fumero <JFumero@nasonyeager.com> I� 1 attachments (443 KB) vm Thu Nov 19, 2020 0937 AM.mp3; Dear Fred, Karen forwarded me your voicemail. I pulled the bills and it looks like the total amount billed and unbilled is $3,206.49. There may be some costs that have not come in yet like process server fees etc. So I think a safe bet is about $3500 for attorney's fees and cos�ts total or so if they settle today. G reg Greg Hyden � �� 5�� I�'c� �� Attorney at Law 1`• ��»�n; i�v:t.�s,�rur,�iKra�at,�. Email: ghyden nasonye�iger.com ; ,tia�>Ftn+�,s:�F �,��w �,�. i,c,�.� Tel: 561-982-7114 � Fax: 561-982-7116 � 750 Park of Commerce Blvd., Suite 210 �Boca Raton �FL �33487 www.nasonyeager.com Profile vCard The information contained in this transmission is attorney privileged and confidential. It is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you receive this communication in error, please notify us immediately by telephone (collect) and return the original message to us at the above address via the U.S. Postal Service. We will reimburse you for postage and/or telephone expenses. WIRE FRAUD ADVISORY: Due to the increased risk associated with wire fraud and e-mail hacking and phishing attacks, in the event you receive an e-mail from Nason Yeager containing wire transfer instructions, please call Nason Yeager using previously known contact information and NOT information provided in the email, to verify the information contained within said wire transfer instructions prior to sending funds pursuant to such wire trensfer instructions. Think Green! Please do not print tliis e-mail unless absolutely necessary. -----Original Message----- From: Karen Chang Sent: Thursday, November 19, 2020 10:09 AM To: Greg Hyden <GHyden@nasonyeager.com> Cc: Stacey Janowitz <SJ,�nowitz@nasonyeager.com> Subject: FW: [0:57] Message for MB 3603 from a caller at (863) 763-9795 Fred Sterling re: Rodriquez - Per the City Attorney, they have made an offer of $3,500 to settle everything and they want to accept that offer. Th�=y need to know how much the attorney's fees to date is for this matter. Please cail him at (0) 863-763-9795 or his (C) 863-634-7208. -----Original Message----- From: voicemail@nasonyeager.com [mailto:voicemail@nasonyeager.com] https://outlook.office365.com/mail/in box/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3Mi04Mjc2LTg1 ZIwNmE4ZmEwMAAQAI G IH6j7U9pPp7sLy5Yggyc... 1/2 11/19/2020 Mail - Fred Sterling - Outlook Sent: Thursday, November 19, 202�0 AM ' To: Karen Chang <KChang@nasonyeager.com> Subject: [0:57] Message for MB 3603 from a caller at (863) 763-9795 This message was sent by your voice mail system. Message received on Thu Nov 19, 2020 at 09:37 AM This email has been scanned for email related threats and delivered safely by Mimecast. For more information please visit http://www.mimecast.com https://outlook.office365.com/maiVinbox/id/AAQkADZIZGU0MTg2LTMOMGQtNDk3M iO4Mjc2 LTg1 ZIwNmE4ZmEwMAAQAIGI H6j7U9pPp7sLy5Yggyc... 2/2 COLINM. �CAMERON,ESQ.,P.A. AttoY�zev atzd Counselor at Law November 12, 2020 Telephone 863 / 763-8600 Facsimile 863 ! 763-2886 200 N.E. 4`h Avenue Okeechobee, Florida 34973-2981 Col in ct CCameroiiLaw�.com R. Gregory H;yden, Esq. VIA EMAIL Nason, YeagE�r, Gerson, Harris & Fumero, P.A. ghydenCc�nasonyeager.com 750 Park of C;ommerce Blvd, Ste 210 original by mail Boca Raton, }� L 33487-3610 re: City of Okeechobee v Rodriguez Case No. 2020-CC-190, Okeechobee County Court Dear Mr. Hyden: I have the pleasure of representing Gloria, Raul ("Rudy") and Noe Rodriguez in connection v��ith the above foreclosure of a code enforcement lien. The Rodriguez's had made arrangements to have the two buildings (the offending single family home, and the shed) demolished. A copy of the contract proposal and the permit (already issued, # 20-11-415) are attached. Estimated cnst to complete is $2,400.00. We propose to complete the removal of the buildings and Co cure of the code violations within thirty (30) days. The lien is 9�11,575.00 pursuant to your complaint (pai-a. 16). We request a reduction of t:his fine, and propose to pay the total sum of $3,500.00 for ttle accrued lien, and the court costs and attorney's fees incurred to date. We would pr��fer to not have to file an appearance or other papers or pleadings in the civil actic�n to ]ceep everyone's costs and legal fees to a minimum. Please revievv this with the City of Olceechobee and advise us. Sincerely yours, C LIN M. CAtvIERON CMC/st cc: Rodriguez's S:\��vii'�R�.Or+p��a.i.lrl'��tik�e�..il)'J... _J�,'ltil�l��i��nllcrl.w�:d t� �' � � , �; R�drywez, J.J. Smith From: Lane Gamiotea Sent: Monday, November 2, 2020 10:52 AM To: Bobbie Jenkins; J.J. Smith Subject: FW: Update on City code enforcement program FYI, print this email for all �files necessary ..... �r�s �a�� E��;o�a, c�rc City Clerk/Personnel Administrator City of Okeechobee 55 SE 3�d Avenue, Room 100, Okeechobee, FL 34974 Office: 863.763.3372 exir. 9814, Fax: 863.763.1686, Cell: 863.697-0345 Under Florida law, email addresses are public records. If you do not want your email address released in response to a public records request, do not send electronic mail to this entity. Instead, contact this office by phone or in writing, Flori��a Statute 668.6076. CITY OF OKEECHOBEL ELECTRONIC DEVICE DISCLAIMER: Florida has a very broad public records law. Most written communications to or from local officials regarding city business are public records available to the public and media up�n request. Your correspondence via e-mail, text message, voice mail, etc., may therefore be subject to public disclosure. , z � � �� ' a ,�rz �`� � e , �- "� �� `�"�,��''�..��' l , ,�.�i��„J�. .��¢i§.�tl�J{'f '..:{ .' ...., . .� .. � ..c.... ,,...__.. _____ ........._-3 From: City Attorney <cityattorney@cityofokeechobee.com> Sent: Friday, October 30, 2020 4:10 PM To: John Fumero <1Fumerc�@nasonyeager.com> Cc: Robert Peterson <rpeterson@cityofokeechobee.com>; Carlyn H. Kowalsky <CKowalsky@nasonyeager.com> Subject: Update on City code enforcement program Dear City Council- I am providing an update on the various code enforcement matters that have been approved by the City Council for forecic►sure, as well as those code enforcement matters which will be considered by the City Council for foreclosure. The pending code enforcement matters are: 1. City of Okeechiobee v. Brenda Kemp et, al.; 19t" Judicial Circuit Case Number 2019 CA 253: this is a foreclo:�ure action resulting from the City's municipal lien/order. On October 30, 2020, I emailed Fred :3terling an Affidavit of Default Amounts Due. Once I get that back, I will set the Motion for Default Final Judgment for hearing. We intend to expedite this matter. 2. City of Okeech�obee v. Gloria Rodriguez et al.; 19t" Judicial Circuit Case Number not yet assigned: this action will be a foreclosure of the City's municipal lien/order. We have finalized the Complaint and intend to file it today, October 30, 2020. After the Defendants are served, they have twenty days to file an Answer. If they do, we will serve discovery pleadings. If they do not file an Answer, we will press forward with a Default Final Judgment. 3. City of Okeechobee v. Teresa Cappetta et al.; 19t" Judicial Circuit Case Number not yet assigned: this action will be a foreclosure of the City's municipal lien/order. We have finalized the Complaint and intend to file it today, October 30, 2020. After the Defendants are served, they have twenty days to file an Answer. If they do, we will serve discovery pleadings. If they do not file an Answer, we will press forward with a Default Final Judgment. I believe that Roy Conerly, one of the Defendants, is dead and so I preemptively drafted the Motion to Appoint Curator so that we could set up an estate for purposes of service of process. 4. City of Okeechobee v. Marvin W. Brantley; 19t" Judicial Circuit Case Number 47 2004 CA 000309: We successful in procuring an Order Finding Defendant in Contempt of Court on September 21, 2020. The Court ordered Mr. Brantley to pay the City $6,297.50 as and for the City's attorney's fees and $9,750.00 as and for the City's fines. Given that it is clear that he will not pay those fees and fines, I emailed Fred Sterling the Affidavit required. Once we get his Affidavit, we will submit same along with a proposed judgment. After the Court issues the judgment, we will record it so it becomes a Judgment Lien. We will also submit it to the State of Florida Secretary of State and get a Judgment Lien Certificate. Once that is done, we will ask the Clerk to issue a Writ of Execution and we will provide that, along with the Judgment Lien, the Judgment Lien Certificate and an Instructions for Levy form to the Okeechobee County Sheriff. The sheriff will then auction Mr. Brantley's property off. 5. City of Okeechobee v. Barbara Mills; 19t'' Judicial Circuit Case Number 47 2004 CA 000309: On October 28, 2020, we filed a Suggestion of Death and Motion for Substitution as the Defendant is dead. The probate attorney agreed to enter into an Agreed Order and that was provided to the Judge on October 29, 2020. Once that is entered, the Personal Representative will be substituted in for the Defendant and he must file an Answer or a Default will be entered against him. We likewise, as a creditor of the Estate, filed a Statement of Claim in the Palm Beach County probate case on October 29, 2020. This property is purportedly homestead but that loses the protection on January 1, 2020. Depending on how this matter proceeds, we may need to file an Amended Complaint. 6. City of Okeechobee v. Crystal l, LLC; 19t" Judicial Circuit Case Number 2017 CA 218: We are waiting for the City's approval to proceed with this matter. The City had initi�ated a foreclosure case against the Defendant on September 15, 2017. On October 28, 2020 we filed a Motion for Default Final Judgment seeking $32,562.50 inclusive of attorney's fees. The Notice of Hearing was filed and the hearing is set for November 17, 2020. The proposed Order has already been emailed to the Judge. 7. City of Okeechobee v. Okeechobee Park Street, LLC (Walgreens); Code Enforcement Case Number 17-040: we have worked with City staff to draft a letter to the property owner advising it that if the current accruing liens are not paid, a foreclosure action will be initiated. Staff has not further advised of the status. 8. City of Okeechobee v. South Florida BBQ; 19th Judicial Circuit Case Number not yet assigned: the 90 day letter was sent to the property owner on February 27, 2020. We are waiting for the City's approval to proceed with foreclosure. . 9. City of Okeecl'�obee v. Fortex Holdings, LLC; 19t" Judicial Circuit Case Number not yet assigned: the 9�0 day letter was sent to the property owner on March 2, 2020. We are waiting for the City's aK>proval to proceed with foreclosure. As always, should you have any questions or comments please do not hesitate to contact me or Carlyn Kowalsky. CITY ATTORNEY CITY OF OKEECHOBEE t.._ C�C� (`''1 ' a��` �I��b�e '�as�;,: �i�e�F �r�.� : - � �1, f . . 11 �.� l��son Yea er --- --- _ - - � GERSON, F{/1RRIS & FUMERO. P.A. A�f7'ORNLYS A( L/1W � Lst. 17G0 R. GREGORY HYDEN E-MA[L ADDRESS: ghyden@n asonyeager. com October 5, 2020 VIA EMAIL: mclose@cityofokeechobee.com City of Okeechobee Attn.: Melissa C;lose 55 S.E. 3`d Avenue Okeechobee, Florida 34974 re: S�tatus of Code Enforcement Matters Applicable Case Numbers Set I+orth Below Dear Ms. Close, �� . ..� � (�� _.:J �� ;� .� �; D[RECT DIAL: (561)47t-3524 FAX NUMBER: (561)982-7116 This firm is proud to represent the City of Okeechobee ("City"). Pursuant to the City's request, I am providing an update on the various code enforcement matters that have been approved by the City Council for foreclosure as well as those code enforcement matters which will be considered by the City Council for foreclosure. The pending code enforcement matters are: Pendin� in Circuit Court City of Okeechobee v. Marvin W. Brantley; 19�h Judicial Circuit Case Number 47 2004 CA 00031�9: We were successful in procuring an Order Finding Defendant in Contempt of Court on September 21, 2020. The Court ordered Mr. Brantley to pay the City $6,297.50� for the City's attorney's fees and $9,750.00 for the City's fines. If Mr. Brantley does not pay those funds within 45 days, we will engage in post judgment collections and request the Court to impose a lien on the property that can be subsequently foreclosed on. This is a great win for the City! 2. City of Oiceechobee v. Brenda Kemp et. al.; 19`" Judicial Circuit Case Number 2019 CA 253: this is a foreclosure action resulting from the City's municipal lien/order. After receipt of the file from the City's prior counsel, we determined that the Defendants had not filed �i responsive pleading to the Complaint and thus we intend to file a Motion for Default F:inal Judgment. We have provided a copy of said Motion, together with the 750 Park of Commerce Boulevard � Suite 210 � Boca Raton, F(orida 33487 Telephone (561) 982-7114 � Facsimile (561) 982-7116 ��vww.nasonveaeer.com PALM BEACH GARDENS • BOCA RATON �� , . ! City of Okeechobee Attn.: Melissa Close October 5, 2020 Page 2 applicable Affidavit of Attorney's Fees and Afiidavit of Default Amounts Due for staff's review and comment. Upon approval, it will be filed and set for hearing at the next available time. We intend to expedite this matter. 3. City of Olceechobee v. Barbara Mills; 19th Judicial Circuit Case Number 47 2004 CA 000309: We are waiting for the City's approval to proceed with this action. The City had initiated a foreclosure case against the Defendant on July 14, 2014. That matter remains pending. Prior Counsel did not advise why the case has not been prosecuted for the last few years. However, upon approval from the City, we will proceed in the pending case. It is likely that the Complaint will need to be amended but the matter can be expedited thereafter. 4. City of Okeechobee v. Crystal I, LLC; 19`h Judicial Circuit Case Number 2017 CA 218: We are waiting for the City's approval to proceed with this matter. The City had initiated a foreclosure case against the Defendant on September 15, 2017. That matter remains pending. Prior Counsel did not advise why the case has not been prosecuted for the last few years. Upon approval, we can proceed in the pending case. It is likely that the Complaint will need to be amended but the matter can be expedited thereafter. Waiting for Citv's approval to file complaint City of Okeechobee v. Gloria Rodrigzrez et al.; 19th Judicial Circuit Case Number not yet assigned: this action will be a foreclosure of the City's municipal lien/order. We have drafted the Complaint and have sent it to staff for review and comment. Upon approval, it will be filed and service of process will be expedited. If, twenty days after service of process, the Defendants do not file a responsive pleading, we will seek a Default Final Judgment against them. 6. Ciry of Olceechobee v. Teresa Cappetta et al.; 19�h Judicial Circuit Case Number not yet assigned: this action will be a foreclosure of the City's municipal lien/order. We have drafted the Complaint for Foreclosure and have sent it to staff for review and comment. Upon approval it will be filed and the matter will be expedited. If, twenty days after service of process, the Defendants do not file a responsive pleading, we will seek a Default Final Judgment against them. Crty of Okeechobee v. Okeechobee Park Street, LLC (Walgreens); Code Enforcement Case Numbec 17-040: We have worked with City staff to draft a letter to the property owner advising it that if the current accruing liens are not paid, a foreclosure action will be initiated. 8. City of Okeechobee v. South Florida BBQ; 19`h Judicial Circuit Case Number not yet assigned: the 90-day letter was sent to the property owner on February 27, 2020. We are . �. City of Okeechobee Attn.: Melissa (�lose October 5, 2020 Page 3 waiting f'or the City's approval to proceed with foreclosure. 9. City of C)keechobee v. Fortez Holdings, LLC; 19�h Judicial Circuit Case Number not yet assigned: the 90-day letter was sent to the property owner on March 2, 2020. We are waiting fbr the City's approval to proceed with foreclosure. 5hould you have any questions about the foregoing, please do not hesitate to contact me. Thank you for your tim�� and consideration in this matter. Many Thanks, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. R. Gregory Hyden R. Gregory Hyden City of Okeechobee Code Enforcement Case #: 18-043 Name: Gloria F2odriguez Property Loca�tion: 914 NW 2"d Street — Okeechobee Code Board A.ction: Imposed a fine starting 06/25/2019 @$25.00 per day for code violation IPMC: Chapter 3 Section 304.1.1 (8) Unsafe Conditions &Section 304.7 Roof Damage. Accrual of Fine: 2019 2020 June = 6 Days January = 30 Days July = 31 days February = 29 Days August = 31 days March = 31 Days September = 3�D days April = 30 Days October = 31 days May = 31 Days November = 3C� days June = 30 Days December = 31 days July = 31 Days August = 31 Days September = 30 Days 463 Days to end of September Total = $ 11,57'S.00 Administrative� Fee - $ Total Amount Due = $ Date of Compliance — IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEF?CHOBEE, FLORIDA, a municipal cor��oration organized under the laws of the State of Florida, CASE NO.: Plaintiff, ►� GLORIA RODR.IGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendarits, / COMPLAINT COMES NOW, Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff' or "City"), by and through undersigned counsel, and brings this action for foreclosure against the Defendants, GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ (collectively "Defendants") arid in support thereof states: Venue and Jurisdiction 1. Tl1is is an action to foreclosure a lien on the Defendants' real property located within Okeechob�ee County, Florida. 2. This Court has original jurisdiction over this action because the City's lien and related damages �do not exceed the sum of $30,000 exclusive of costs. 3. Venue is proper in the Nineteenth Judicial Circuit because the property in question is located in Oke��chobee County, more specifically, Okeechobee, Florida. 3. The Defendants' own real property located at 914 NW 2°d Street, Okeechobee, Florida 32643-64�03 and legally described as follows: Lot 17 a�nd the East'/Z of Lot 16, Block 132, Town of Okeechobee, according to the plat thereof recorded in Plat Book 2, page 17, Public Records of Okeecho�bee County, Florida. Subject �to all restrictions, limitations and covenants running with the title to the property. Subject property is the homestead of the Grantor. ("Properly"). A true and correct copy of the Warranty Deed is attached hereto as Exhibit "A" and incorporated by �reference herein. 4. The Property is not homestead property and not otherwise exempt under Article X, Section 4(a) of the Florida Constitution. A true and correct copy of the applicable 2019 Notice of Ad Valorem Taxes & Non-Ad Valorum Assessments is attached hereto as Exhibit "B" and incorparated by ��eference herein. 5. P�ursuant to Florida Statute Chapter 162, the City has the right and obligation to enforce its Cod�s and Ordinances within its boundaries and has the authority to foreclose applicable liens :;temming therefrom. General Allegations 6. By way of background, on or about October 23, 2018, the City sent out a Notice of Violation to the Defendants relative to the Property's unsafe roofing and inadequate drainage. The matter was eventually referred to the Code Enforcement Board in matter number 18-043. 7. Tlhereafter another Notice of Violation along with a Notice of Hearing before the Code Enforcem�nt Board dated January 18, 2019 was sent to the Defendants via Certiiied Mail with Return Recf�ipt Requested. Noe Rodriguez signed the Return Receipt on January 22, 2019. 8. Tlhe Special Magistrate conducted a hearing on June 25, 2019 and subsequently entered a Lien/Order imposing a fine of $25.00 per day until the violations were correct. 9. The Lien/Order is recorded in Book 828, Page 1250 of the Official Records of Okeechobee Co�anty, Florida. A true and correct copy of the Lien/Order is attached hereto as Exhibit "C" and incorporated by reference herein. 10. By way of letter dated October 17, 2019, the Defendants were advised that the daily fines of $25.00 r�ad accrued for over 90 days and that this could result in foreclosure. 11. A.11 conditions precedent for bringing this action have occurred or been performed. Count I — Foreclosure 12. The City realleges paragraphs 1 through 11 as if fully set forth herein. 13. P,ursuant to Florida Statutes Section 162.09(3), if a valid lien remains for a period of 90 days and does not otherwise come into compliance, the City may elect to file a foreclose the lien. 14. As of the 90th day, and at all times since, the said lien has not been satisfied and the Property has not come into compliance with the City's Code of Ordinances. 15. In� addition to the various mailings, the City has posted notice(s) of lien on the Property itself. A true and correct copy of photographs of the posted Notices are attached hereto as Exhibit "D" and incorporated by reference herein. 16. Tlhrough September 30, 2020, the Defendants owe the City $11,575.00 plus attorney's fees and costs. Additionally, the fine continues to accrue at $25.00 daily thereafter until entry of the judgment of foreclosure by this Court. 17. T1'ne City believes that there may be additional persons who may be interested in the Property, but after a diligent search and inquiry remain unknown to the City. 18. Tl.�e unknown parties may claim as heirs, devisees, grantees, assignees, lienors, creditors, trustees, or other claimants by, through, under or against the Defendants herein, and therefore all of the said unknown parties are made defendants to this action. 19. T:here may be other unknown parties having or claiming to have some right, title or interest in the subject matter of this action, but whose names after diligent search and inquiry are unknown to the City. Diligent search and inquiry has been made to discover the names and residences of any unknown defendants, but their ages are unknown, their residences are unknown, and the City does not know, by, through, or under or against whom they may claim, nor what right, title or interest thiey may claim in the Property. 20. TP�e City has expended, and will expend during the pendency of this action, certain necessary costs and shall seek reimbursement of same. 21. Further, the City has retained the undersigned counsel as its attorney in this action and has agreed t:o pay him a reasonable fee for said services. The said fees are an additional indebtedness autTlorized by Florida Statutes Chapter 162. WHEREl ORE, the City respectfully requests that (a) this Court enter a judgment of foreclosure, warcl the accrued lien(s), expenses and costs, including attorney's fees and costs, plus interest to the City; (b) if the said sum is not paid within a time set forth by the Court, the City requests that the Property be sold at auction to satisfy the City's claim; (c) if the proceeds of the foreclosure sale are insufficient to pay the City's claim, that a deficiency judgment be entered for the sums remairiing unpaid against the Defendants herein; and (d) such other relief as this Honorable Court deems just and proper. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Blvd., Suite 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 � Facsimile: (561) 982-7116 E-mail: ghyden@nasonyeager.com Attorneys for the Plaintiff Florida Bar No.: 50839 By: R. GREGORY HYDEN •�w'iai�u �a Landmark Web Otlidel Records Search CODE ENFORCENIENT SPECIAL MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA CASE NO. 18-043 CI'CY OF OKEECHOBEE, PETITIONER, -vs- RESPONDbNT, _ Gloria Rodrigy�ez / I,lEN / ORDER 1'HIS CAUSE came before the Cade Enforcement Board, City of Okeechobee, for public hearing on .tune 25 , 20 l�. After due.notice to the respondent, the $oard having heard evidence on the alleged violaHon by wimesses or af�davlt makes the following findings: A. FINDIlVGS OF FACT: Lots: 17 8c E%a of I.ot 16 Blk: 132 Section: City of Okeechobec Patcel: 3-15-37-35-0010-01320-0160 Propccty location: 914 NW 2"'' Saeet, Okeechobee, FL Propecty owner: Gloria Rodriguez Praperty has been found to have an unsafe housa with roof damage which needs. to be demolishcd. B. CONCLUSIONS OF LAW: The owaer of thc property describcd above has been found in violation ofInternetional Property Maintenence Code Ch 3 Sec 304.1.1(8) Unsafe condition and Sec 304.7 Roof damage C. ORDER: The City of Okeechobee Code Enforcement Special Magishste has detemtined you violated the Intemational Property Nfaintenenco Codq Ch� Sec 304.1.1(81 �i afe condition �nd Sec 304 7 Roofda� agg concerning yourproperty loceted at 974 NW 2nd Stre ot. Oke•�chobee Fi . if you do not conect the violation before June Z5. 2019 _ or notify Ute Code Enforcement ptiicer of the correcRion, the Magistrate Imposes a fine of S 25.00— per day commencieg thet date and continuing daily until Ute violation is corrocted or the city is notified by yau and verifies the correction, which ever fust occurs. Further, if you do not correct the viotsition by seid date, a copy of this order as a claim of lien, sha11 be recordcd in the oPfice of the C;Ierk of Circuit Court, Okeechobee County, Florida, and onco recorded, becomes a lien � on n:ai and personal property pursuant to Florida Statute 162. You hav� a right w3t�in tLirty days,, to appeal t}�s finding e�d order by Writ of Certioran to the Cirouit Court, Okeechobe� Cow�ty, Florida. If you cocr�ct the viotetion prior to the above date, it is your obligation to � aontfict the Code Enforcement Officer to verify such complience. � 800k828/Page1250 CFN#2019008'106 Page 1 of 2 �rN� � �_ g�� oy�� e �� Nm� �� NKw � �V N�o a= hqpsJlploneer.okeechobeelandmark.com/LandmarkWebUve/search/index?lheme=.btue&ssctlon=searchCdteriaNameBnulckSearchSetec4on=# �/� ..viv.�w �iuuavav va.. ............... �.........) �..... �....�..�..,. __ i ... . . . � 1 f �� `� i � Print f3ill Notice Of AD Valorem Taxes & Non-AD Valorem Assessments Bill # R 3000300 2019 R 3-15-37-35-0010-01320-016U REAL ESTATE Tax/Notice Receipt For OKEECHOBEE County AD VALOREM TAXES RODRIGUEZ GLORIA, ETAL. TAXING AUTHORIIY M1lLAGE RATE TAX AMOUNT C/O NOE RODRIQUEZ courrtv .00n0000a 5139.90 17324 NW 213TH DR SCHOOL-RlE .00383900 sn.o9 HIGH SPRINGS , FL 32643 - 6483 SCHOOl.-UISC .00224800 S'11.63 CifY-OK[f-CHOBEE .OU760180 5132.94 0.258 ACRES SOUTH FL'NAT hIGi4NT .00027950 sa.av CITY OF OKEECHOBEE CH(LDRCNS COUNCIL .00036000 $6.30 LOT 17 & E 1/Z OF LOT 16 TOTAL AD-VALOREM: 5396.75 NON-AD VALOREM ASSESSMENTS BLOCK 132 TAXING AUTHORiTY � � TAX AhtOUNT FAIR MKT VALUE $19,517.00 DIST Asmt - EMS ASSESSMENT 5303.53 Asmt - GARBAGE ASMi CI 5237.96 qSSESS $17,488.00 EXEMPT VALUE TOTAL NON-AD VALOREM: $341.49 COMBSNEDTAXES&ASMTS: ;738.24 TAXABLE VALUE $17�488.00 o:scounr: so.00 ** PAID ** UNPAID BALANCE: $0.00 �ast Payment: 03/31/2020 Receipt Number: Exemptions: Amount Discount Collected: �738'24 Amount: Property Address: 914 NW 2ND ST OKEECHOBEE 34974 Tax Roll Property Summary Parcei Rall Type Year Or(gtnaf Gross Tax Origfnal Assessmen[s Date Paid Amount Patd Total Unpaid 3153735003D013200160 R 2019 $396.75 5341.49 3)31/2020 $738.24 ;0.00 315373500100132QUI60 R 2018 537M1.47 ;33815 3/31R020 $902.75 50.00 31537350010013200160 R 2017 5334.99 $312.ib 3272018 $647.15 $0.00 315373500100132001b0 R 20ib 5320.74 ;310.64 3/31/2017 $631.36 50.00 31537350010013200160 R 2015 �675.98 5309.20 3(31/2017 $1,279.10 ;0.00 31537350010033200160 R 2074 $1733 $295.12 12/30/20i4 $303.08 ;0.00 315973500300i320D160 R 20i3 $7.96 $291.52 3/2E12014 5299•'18 �0.00 31537350010013200160 R 2012 534.32 Sz91.24 3i12/2013 ;325.56 $0.00 �VISUALGOV � "'"'""""'"'""°""' D&T Ventures pt rghts re5erved. Copyright OO 1999-2019 P�_�y 50 ;0.00 9833926 $0.00 1 of 1 9/25J202�, 1:53 PM c� ��— Witness Signaturc �p. -�tA--�-. A,�a /� _.__ Witness Printed Narne STATE OF FLC�RIDA COUNTY OF OKEECHOBEE I HEREEtY CERTIFY that on this day, before me, an officer duly authorized to administer oaths and takc acicnowledgments, personally appeared GLORIA RODRIGUEZ, laiown to me to be thc persons described in and who executed the foregoing instrument, who acknowlcdged before me that she executed thc same. (� Said person(s) is/are personally known to me. (� Said erson s) provided the following type of identification: ��r : da �Ga C�r�.l � WITNES�S my hand and officia) seal in the County and State last aforesaid this 1'g day ofJuly, 2U11. •f �ti PAINELLA 8. MNOI.D �'; MY COIdM16310N � DD 710570 EXPIRE8;3�ptMnb�r3,2011 �, „ ; eo�.a n,n� ►ra+�r r�crc una�,+Mn �� . Q,�,�.�� Signature of Notary "7 C!?+ c / �� J • il �n� �d _ Print Notary Name My commission expires: 1 hereby certify �hat I have prepared this instrument from information given to me by the parties heret4. I do not guarantee either marketabilily of title or accuracy of description or quantity of land described as I dicl not cxamine the title to thc properiy involved. Q.,.�L7fl'2 /��r+�1 �lA F, r`CAI-1�'�f1� � flll7�l�'� �r+��+ 7 r►� 7 . , ...� r , �_i L. � � This h�strument Prepared and Return to: Colin M. Cameron, Esq., P.A. 200 N. E. Fourth Avenue 4keechobee, FL 34972 Parcel No. 3-15-37-35-0010-01320-0160 Cl �' L? K�� i=� 7� i.,� F' G 1 �� 4 4 ON ROBEfiT50Nr CL.Ef�Y OF CIfiGUIT CpUhT GHOBEE GOUNTY� FLOkIDA FECQfiQEO ii7/�il/�i]11 U?;53o51 F'f1 AMT 1��.��il kECORDING FEES 31E.5U DEEU DOG 4i i. 7� � F�EC:OF�DED eY R F'arr i sh F'95 ��44 - i��i i�p95I THIS WARRANTY DEED, made the � day of July, 2011 by GLORIA RODRIGUEZ, a single woman, herein named the Grantor, to GLORIA RODRIGUEZ, a single woman, RAUL RODRIGUE7,, a singlc man, and NOE RODRIGUEZ, a marricd man, as jaint tenants with ri�hi of survivorship, whose post office address is Post Office Box 533, Okeechobee, FL 34973-p533, hersinafter called the Grantees. WITNESSETH, That the Grantor, for and in consideration of the sum of $10.00 and other valuable considerations, receipt whercof is hereby acknowledged, hereby grants, bargains, sells, alicns, remises, rcicases, conveys and confirms unto the Grantecs all that certain land, situaie in Okeechobee Couniy, State of Florida, viz: Lot 17 and the East % of Lot 1 G, Block l 32, Town of Okeechobcc, according to the plat thereofrecorded in Plat Book 2, page 17, Public Records ofOkeechobee County, Florida Subject to all restrictions, limitations and covenants runr�ing with the title to the property. Subject properiy is the homesteaci of the Grantor. TOGETHER, with all the tenements, hereditaments and app�irtenances thereto belonging or in anywise appertaining. TO NAVE AND TO HOLD, the same in fee simple forever. AND i}ie grantor hersby covenants with said grantee that the grantor is lawfully s+eize�l of said land in fee simple; that the grantor has good right and lawful authority to sell and convey said land, and hereby warrants the title to said land and will defend the same against the lawful claims of all persons whomsoever; and that said land is free of all encumbrances; excepi taxes accruing subsequeni to December 31, 2010. 1i�1 WI�'NESS WHEREOF, the said Grantor has hereunto set her hand and seal the day and year first above written. Signed ealed and delivered in the presence of • � . w � �Ji ne Signature GLC3RIA �i.ODR.I�UEZ t Post Offic+e Box 533 �tv�,�-•�. �,� \ [o n Ok�echobcc, FL 34973-0533 Wifiess Printed Name Qrsr►li7!'f'3/�n��1 f1�1 d �''CAI#�!» 4 r1f�7�'IG7 D.�r+�� 7 r�f � 5HARON ROBEFTSON CLEP,K & CUMPTROLLER OKEECHQBEE COUNTY, FLORI�A 312 N.�. 3 STREET, SUITE 155 OKEECHOBEE, FL 34972 863.763.2131 REF: DATE:8/2/2019 TIME:12:07:40 PM RECEIPT: 201J006667 - DUPLICATE - CITY OF UKEECHUBEE ACCOUNT #: 0 DUPLICATE RECEIPT ITEM - 01 L'IEN RECD: 8/2/2019 12:07:40 PM FILE: 2U19008106 BK/PG 0 828/1250 CITY OF OKEECHOBEE RODPIGUEZ GLORIA P,ecording Fees 18.50 Subtotal 18.50 ITEM - 02 SAT RECC: 8/2/2019 12.:07:40 PM FILE: 201900810? BK/PG 0 828/1252 CITY OF OKEECHOBEE BERTRAM ANTHONY Recording Fees 10.00 Subtotal ].0.00 TOTAL DUE $23.50 PAID TOTAL $29.00 PAID CASN $2y.U0 C�1SH RETURNED ($0.50> -------------------------------- REC BY: M PINON DFPUTY CLERK www.clei,k.co.akeechobee.fl.us _-� MapPrint_Okeechobee-Countv-Property-Appraiser_3-10-2020 f � Page 1 of 1 '�s_ -: _ -_ . � .,..;r•.�- � �1�'°�.�i� ="�'z'�191�R�` � �:; i7l��::t � �er . ^. �.�. � ` v,;R . . . . �. � � .` � -_ \ � ... . _ ,r � t _�.._"�"�`".'k, + r.� � ._.,,:4 � . . . � ,A � ' � ;�,= ,.. ti�, � � . � , �� 0. �_ ' � _�� ,........ � � � �.. �""'` - � ,� . • � w �` r . � ��= � � � �� ,,, � 4 J I.� ��` �. �"�- �� 4 u r� . � � ' ��'�fI_ __.� � . � I+ �: cL ti � 1 � a 1i.'W� ` � } - �' -_.,�. �,.iY 1i.�'� � � � i� ,' , �i� � � k�Ti..�.oit +.�� 1Rlr� i. i � -a ai � ,�F�r - � 't i �� '�' �`�� - � � �� • ~'��. � _ .�k .�.� �� ,�� „' � M�ib��. � ' , ' "aa i ¢ .� !�� !�r" �''`` , .�"'�` �1.� � � �3 �� •+t- , � .�_' . � 4 ��. _ �� ' �`- r . �c r �` �..��.f:jfU � � ��. , .'� .!i- . g Ji� F1'Jv �RG �T - '~ � �"1i'�t �`.� �t � +•.�1►ii .1�' . +� � ,.�� •�' � �,. , �r - �.�"' �1. 1'�" 1. it ri . 1► . � j . ... .� � �r:1M;� ��: �� `+ �-�� '�� rY tR �' � 4 I ■ �'� ;.� �� ,a ,�'� �' �s �� .-�x� , � << - _ � �,t� � �� , - - �� • �," . � � - �a , �i,,�;- k'�Y ��a�-yr��' ,.Ws. 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Bandi � Okeechobee, Florida � 863-763-4422 PARCEL: 3-15-37-35-0010-01320-0160 � siN��E FaM (000�oo� � o.zss ac NOTES: CITY OF OKEECHOBEE LOT 17 & E 1/2 OF LOT 16 BLOCK 132 RODRIGUEZ GLORIA, ETAL. 2019 Certified Values � � Owner: C/O NOE RODRIQUEZ Mkt Lnd $7,500 Appraised $18,517 17324 NW 213TH DR HIGH SPRINGS, FL 32G436403 Ag Lnd $0 Assessed $18,517 - Site: 914 NW 2ND ST, OKEE:CHOBEE B�dg $9,134 Exempt $0 • XFOB $1,883 county:$17,488 t Sales �neizoii sioo i �u� ' ��%- Info ivvtsss se,soo i�o) Just $18,517 Total city:$17,488 Taxable other:$17,488 school:$18,517 Okeechobee County. FL ihis information„ was derived from data which was compiled by the Okeechobee County Property Appraiser Offce solely for the govemmental purpose of property assessment. This information should not be relied upon by anyone as a determination of the ownership of property or market value. No warranties, expressed or implied, are provided for the accuracy of the data herein, iPs use, or iPs interpretation. Although it is penodically updated, this information may not reflect the data currently on file in the Property Appreiser's offce. GrialvLoaic.corr http://g4b.okeechobeepa.com/gis/gisPrint/ 3/10/2020 �� ' LT�� I��a��t co�r�ct� � t�� ic��t�a�. d��c��d herein, '�y t�� dat� s�t fo� A� �o�tac�s �e �.d�s��d. Co� I��►pector to v��i� cc�m�lia�ce. N�TI�CE IS I�RE�Y C� � t�� t�e a1le�ed '� vi�a�ion(s) ��e presepn�t�d in t�e Cit� C�� C�b�Ce�s, C' Ha11, �Y ' S� �� 3rd Av�n�e, C��e��c�b�, �'�, �� da _.��.. y � o� �� : � � . �� _ �'� D��i � '� c� of th� �.� af � �� . t�� : �ar of �� , , .��.. � ; _ .. Y �i�a�d: 0 � � - �_! " �..o �!j /■ N � =n� r�� .�.-- 5� SE �rd A��uu� - ��c��, �I, 34�7�# 8f 3��l�► .. ZG� �Z�� a� s� �os �x�� h��-� �� CASE NO: 18-043 l. My name is Fred Sterling certified code inspector for the City of Okeechobee and I've been duly sworn in prior to presenting evidence. 2. Respondents(s;► Gloria Rodriguez is/are () present or () not present. The property is occupied by (x) owner(s), O tenant or O vacant. 3. This case concerns property located in the municipal boundaries of the City of Okeechobee at 914 NW 2°d Street . According to Official Records of the Okeechobee County Property Apprz�iser the owner(s) of record is/are Gloria Rodri�uez City exhibit no. 1 4. On April 12, 2018 , I personally inspected the property and observed the following: a. Damagf;d Building b. IPMC Ch 3 Sec 304.7 (Roof Damage) c. 5. Based upon my� investigation, I issued a courtesy card/letter to Respondent(s) notifyingthem of the violation with a request to have the property come into compliance within 10 days. 6. On `1 I�� l Ci I reinspected the pro erty and fou d it still in violation. A Notice of Violation/Notice of Hearing was issued on ° �� and delivered by: ( ) Certified. mail. ( ) Personal hand delivery. (x) Posting Notice of Violation/Notice of Hearing on the subject properry. City exhibit no. 2 7. Notice of Viol�tion/Notice of Hearing gave Respondent(s) days to correct the following violations: a. Ch 3 Sec 304.7 IPMC for violation of Roof Dama�e b. Ch Sec for violation of c. Ch Sec for violation of 8. Prior to the hearing, a final inspection of the property was done and Idetermined: () Property had come into substantial compliance with cited Codes. (x) Property remained in non-compliance. 9. I request in addition to my testimony, all exhibits, notices and photographs be admitted into evidence by th�� Magistrate. Requestin� to �o to_Citr� Council for Recommendation of Foreclosure - Case is well past 90 dav Amoui►t Due as of 10/31/2019 �3,22�.00 , 11/5/2099 Mail - Fred Sterling - Outlook — � � `+t ,r 't� � � _ m, . ..,� , � ��T.f�--�-'�'' - �� ' R v t�` . �,�� 3 ,w.��t y �. ---�-`' �"'�-�-• .t !� , -�,.y. - � Fd � . . f � + � R' -_ ` . ,9' -�,... J . 't�' � . �~I ';�, ' �� t • �F . ,;, �`�Vti�." t'... {�`�_�_•t�. � J� 4. �� p�" � �ti . �,.,. 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' �+' =* al3C=�- � '+ �"�D3;ea =' .r � • . • � _ ''"aa��!�� ,,, � �a�t'�++�.c;;,: _ �".} IIi�S GL �l�Ci.� C-�..�t1 � J https://outlook.office365.com/mail/deeplink?version=2019102702.12&popoutv2=1 3/5 Melissa Close From: Sent: To: code enforcement <codeenforcement7208@gmail.com> Friday, November 01, 2019 1:18 PM Melissa Close %_� i -, 1'1 L. - . . � �. . . � . , i^ 7 ��.,�, �K' ` "� #��,-�S; �. • � • t � 3- � `� .. _ > -'•�• �.�,�,��.� : �, . a . , . . ��t��h' .��..�� `Y � 4 • , ' . � ., . * � w,t . ! . '-ti.�,,;r�`„. . 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Petitioner, vs Respondent, Gloria Rodriguez 863-763-9795 Phone 863-763-7804 FAX Date 10/17/2019 CASE NO. �$'043, Sl�'l"I�EN[EN�I� OF �IIOL��TIOI�1 <lN�D NOTICE OF :IEAIZING � .�- ,,, 'oMpOli �FEF-_.. �1 , _�.-�FL.�.:' Pursuant to Florida Statutes 162.02 and 162.12, Florida Statutes, and the Code of Ordinances of City of Okeechobee, I(hereinafter the "City of Okeechobee), the undersigned Code Enforcement Officer hereby gives notice of an uncorrected violation of the City of Okeechobee Code, as more particularly described herein, and hereby requests a Hearing be; ore the Okeechobee City Code Enforcement Special Magistrate. 1. Violation of City Code Chapter/Section: Ch 3 SeC 304.1.1(8) & 304.7 2. Address and Parcel# �vhere violation exists: g14 NW 2nd Street 3-5-37-35-0010-01320-0160 3. Name and address of property owner or person in charge of location where violation exists: Gloria Rodriguez: '17324 NW 213th Dr - High Springs, FI. 326436403 4. Description of violation: Unsafe Conditions & Roof Damage Recommendation to City Council for Foreclosure, Past 90 Days (see attached letter) 5. Date violation must bf; corrected by: 6. Date violation first obsei.v�d on or about10/23/18 Unless Respondent corrects the ��iolation described herein by the date set forth above AND contacts the undersigned Code Inspector to verify compliance, �vith the Okeechobee City Code Section(s) cited herein, you are hereby called upon to take notice that a Hearing will be hel<i in this cause before the City of Okeechobee Code Enforcement Magistrate on the � 2th day ivovemper at 630 P.IVI., located at 55 SE 3rd Ave Okeechobee City Ha11, Okeechobee Florida 34974 in Council Chambers. The Magistrate will r��ceive testimony and evidence at said Hearing and shall make findings of fact and conclusions of law as are supporl:ed by the evidence and testimony, and shall make an order thereupon. You are entitled to be represented by counsel, present e:vidence, and present testimony. Please be advised that any evidence presented to the Magistrate for his consideration ��vill be retained by Code Compliance Department. If you fail to a pear at the hearing the Magistrate may enter an Order o:f Violation, & impose a fine in your absence. , ..- � �� - ��e�l Sterl' g Code Enf cement Officer Any Person desiring to appeal any decision of the Code Enforcem nt Spe�strate with respect to any matter considered at this heazing will need to ensure that a verbatim record of the proceedings is made and that the record includes the testimony and evidence upon which the appeal will be based. Code Enforcement Magistrate tapes are for the sole purpose of back up for the official records of the Code Enforcement Department. In Accordance with Fla. Statute 162.11(2005), an aggrieved paz�ty may appeal a final administrative order to the circuit court. Such an appeal shall be filed within 30 days of the execution of the order to be appealed. Okeechobee City Code Enforcement 50 SE 2nd Ave Okeechobee Florida 34974 De acuerdo con la seccion 162.11 dc: los estatutos de la Florida, un partido que no esta en acuerdo puede apelar una orden administrativa fmal a la tribunal de circuito . Tal apelacion sera archivada en el plazo de 30 dias de la firma de la orden que se apelara. October 17, 2019 Gloria Rodriguez C/O Noe Rodriguez 17324 NW 213tr' Drive High Springs, Fl. 326436403 Re: 914 NW 2°d Street Okeechobee, Fl. 34972 Case# 18-043 Dear Property Owner: This letter is in :reference to the Code Enforcement Order dated June 2019 notifying you a twenty-five dollar per day fine was imposed as of June 25, 2019 against the property listed above for failure to comply with City Ordinances. As of September 2019, the fine had accrued over ninetv (90) days. According to Florida Statutes Chapter 162 the City possesses the ability to file a foreclosure action against the properiy to colle��t the fine. This action could result in a financial burden on you, in addition to the fines. At this time no fi�reclosure action has been taken against the property. However, you should contact me imme;diately. Failure to contact our office could result in a foreclosure recommendation by the Code Enforcement Special Magistrate. Please �c�ntacl m� at 863-76 �- 9795 to discuss this �n�ltter•. Sincerely, , � ' -� �>�� d Sterling � City of OkeechoUee Code Enforcement Officer (863)763-9795 MapPrint_Okeecho��ee-Counry-Property-Appraiser_9-13-2019 � � I' ��. �� . ,�� _�� v�, =-;�..,�:�.� � a .�w � - 5 - - -. � �► � _..._� ' �--- �-. �. � � ' r 4 ��" �* ` � � �� .,� - � � �-:L '� � -,.�+ � �,��.�~�� ` - a� a�► � �Is�i �'�" - � r �� _ ,• �� '',,, _ � � � ��, � �� '4 - � - '� �` � � � . ,N,Ai* � t • � � � �'i�5�4 '� i� [i ��j � . �� ' .,,..�-� �..� 1� � � i4,w,.., � j"y � � ' � � �! � �.� . � ' ,� �t �� . � � �f �71Fi , . � • ' '"sia. ��c' � M 7,.�..;..1 . __ . ., - . �� . , _ . �` � �� ' � � ' ^� t ' & � � �illl �- . - ' � S y f - .. �� _ � � ��F .�Y� a ,� F_ . � �, � �; �� , �,,� ,,,,_ _ ��, l.s �� 14 t R ��'-�I +�,� ` �� : _� � � = f i � ��:�r'��i,ir �.�: �. �k 1 ' !� . _ . ..-a. w � w.��,s. _ ��' _ �:` `-�!� i,.,. ;:..'�- �+�r�►�, i � ' ` � � ' e` � �� 6 M � � � ._ � �� ---••� � � ��,y1 ` . � ` *� • � �!� � �� . � ��{ ��. ! � � :�- �i � +► a ��[ ' . �.....�� ...• , � � '�� '� �'�4 � �i�� I'�"" + �' - . • , Y � �'`i�'�„ �t �le �I�► r�. id� �T � � , � �. � � ' � ♦ � � �I� 1 _ � � " '. „ ��r �'�� `� ��- .'r' !�s ..�� _ fi � �. ...�� .�, ,� . �� . � A � � _ � . t � �C i �, ., . : �� `,,�,,.r..�f� '�. t-��! ",+� �� . . _ _ . „ � Li' J: � � ' � .��-�lP ��ir.� . ...,,.. �` `� ♦��- y /� T � � �l M�1 ' ..�..�.�. ��} '� . � � �; i_ .:� �� 1�,..la �r�,� � . � �� . . �� l. �^ . . _ �.__<. , �l � � 0 13iJ ^�,r� 3sj0 r. _ Page 1 of 1 � tw,a .l. , � .� � �� , .{' • i �f r � � � ��: %'� ae1 �� .l M " a • �, i .�� y� � f^ a •� � : �: LL �� . r ;n ` d.. � ��R ?0 �N ��+ .* � � s - � 5 r . — � ., . ,a 2 . r � P � � . T Y� � � � k � �� _ .,_5W P,aRr. sT • •- . _ .i �__._ .� . _ 5�q g�q ;3n SrIU 1��4+! 11?I_l � n * � G -a 2 � ��_ T M �� I;Uii it Okeechc►bee County Property Appraiser M��key �. ea�a� i okee�nobee, Florida � 863-763-4422 PARCEL: 3-15-37-35-0010-01320-0160 � sw��e Fa,nn �000�oo> � o.2ss nc ��'��=�: CITY OF OKEECHOBEE LOT 17 & E 1/2 OF LOT 16 BLOCK 132 RODRIGUEZ GLORIE\, ETAL. 2019 Preliminary Certified Values � Owner: C/O NOE RODRIQUEZ Mkt Lnd $7,500 A ppraised $18,517 17324 NW 213TH DR Ag Lnd $0 Assessed $18,517 HIGH SPRINGS, FL 326�436403 Site: 914 NW 2ND ST, OKEEC:HOBEE Bldg $9,134 Exempt $0 Sales 7neizoii gioo i�u) XFOB $1,883 county:$17,488 Info ivv�sss ge,soo i(Q� Just $18,517 Total city:$17,488 Taxable other:$17,488 school:$� 8,517 >� ♦� �� _...�.,cho'�=2 +�o:atTc;+, -_ i rns infortnation„ was derived from data which was compiled by the OI<eechobee County Property Appraiser Office solely for the govemmental purpose of property assessmenL This information 1 should not be relied upon by anyone as a determination of the ownership of property or market value. No wartanties, expressetl or implied, are provided for the accuracy of the data herein, iCs I use, or iPs interpretation. Although i[ is periodically uptlated, this information may not reflect the data currently on fle in the Property Appraiser's office. �� -�. : ' � .. "_� , •� '� �.L L� � ',_.. �--Ci.). -1 C-_ y �,/i1,- �i �--. � http://g4b.okeechobeepa.com/gis/gisPrint/ 9/13/2019 6 .__... . . . _.__._.. "c...u.a;..�..iz� 'k! � «�=. ' . Frr`�.yS,*��k�'M14:, % � � • • '�i • i • '■ Complete items 1, 2, and 3. A. signature ■ Print your name and address on the reverse X so that we can return the card to you. �■ Attach this card to the back of the mailpiece, B• Received by (Printed Name) or on the front if space permits. I 1- /��Iw A[itiraeeqri im � GT,ORIA RODRIGUEZ �'�� NvE I'�.vDP�i�iu�Z 173 �� NW 213 �`' DRIVE HIGH SPIZII�TGS, FL 32643-0643 ❑ Agent ❑ Addressee ' C. Date of Delivery. D. Is delivery address different from item 1? ❑ Yes If YES, enter delivery address below: ❑ No II �'lll�l I�I� I'I I IIII I! I I II II I�I II� � I II ��I ��II 3. Service Type ❑ Priority Mail Express0 I ❑ AduR Signature ❑ Registered MaliT^� ❑ Aduit Signature Restricted Delivery ❑ Regfstered Mall Restricted 959d 9402 3008 7124 5533 76 � Certified MaI10 Delivery ❑ Certified Mail Restricted Delfvery ❑ Return Receiptfor ❑ Collect on Delivery Merchandfse 2. Article Number (Transfer from service /abel) ❑ Collect on Delivery Restricted Del(very ❑ Signature ConfirmationTr^ "" tail ❑ Signature Confirmation 7 � � 6 2 7 6 0 0 0 0 2 9 5 9 0 8 8 Z 3 ' 1��i1 ResMcted Detfvery Restricted Delivery •, PS Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Return Receipt � f � F' k 4, S —��n °�9t5° City of Okeechobee 55 S.E. Third Avenue • Okeechobee, Florida 34974-2932 � � �`� v �� 'L`k�. . � �� 1 �� i � 5 �,.: Ck� �a � �$ t �`f � � � N f� ��{«� � � � � } �.s'..� _" . �� a11'i� 1j'S� '.A�-+`"<-i 70�6 2760 0002 9590 �823 � � . ....�:.... ..-.� . -��i',SI-�� /l„JJ i':i�iiiL ) J - -� _...� . .. � .. ._ � 5 . :: :..::.:::. . . .. ... ...... ..S � � � �i`1 i/,i �' �'"�r '{ L�,i'��° v.,.,r.3_ � . 5�"t, ..."..__"__.._.:-_._...�=� .:L:i i'.:,r.iLl� . `._ :t;��,!,�.i . 3 GLORIA RODRIGUEZ (�, �_ �,_, �, G ��y ' c/o NOE RODRIGt1EZ 17324 N��V 213TH DRIt'E HIGH SPR.INGS, FL 3264�-OG�3 �v15. iy� w , :,. ._r: : `>,� � � _.. .. , _„ : �� => ; ;PJ `� ��] r. ��. �}. 7/�. . t : �.. �..:f.i �. �_ .., s. t"s iJ 6: r. 'i � 5 s i'a,!S• j-.. r' . .> ` t..� . . . ,. - . . . r>. �, i � L. �:i.:.::�: ��IF �,f't.".':^r�'i w. �i.�3i;�. � �.. � . : � `�'' . . �. ..� r 6.' �` :w ' v. m u% .ry - ,.. ., t: i:� �S � : � � sijsi-. - �"�#P�a ��5 ��ifii';;�'� ., fi a��.fijii�ll�fi� . ;i�. CITY OF OKEECHOBEE CODE ENFORCEMENT Case: # i 8-04_. Name: G�loria Rodriguez Property Location: 914 NW 2°d Street Parcel: 3 -15-37-3 5-0010-013 20-0160 Code Board Action: Imposed a fine starting 6/25/19 @$25.00 per day for code violations of the International Property Maintenance Code Ch 3 Sec 304.1.1(8) Unsafe conditior� & Sec 304.7 Roof dama�e Accrual of Fine: Jun = . �� ic'�` � �� July = .:a ! �`1 � u = � � ; ��'%J' � 2\ �r �, Se t� _ �� %�� V(:L = �11 (.�� Nov = � Dec = �� n °,1�'� l� l � TOTAL = o�. J�' � Ga. C� Q� (�,�j � ��"��—�q' 1 �4 c�a.c-�`.� = � 3, �-� .�c Date of Co�ipliance: __._. CODE ENFORCEIVIENT SPECIAL MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA CITY OF OKEECH�OBEE Petitioner, -vs- GLORIA RODRIGIIEZ Respondent(s) NOTICE OF VIOLATION ! NOTICE OF HEARING CASE NO. 18-00043 Pursuant to Florida Statutes 162, & Chapter 18 Section 18-33 of the Code of Ordinances of the City of Okeechobee, the undersigned Code ��cer, being first duly sworn, and with personal knowiedge of the facts, hereby alleges the existence of uncorrected violaticns of the Code of Ordinances and gives notice herein to the landawner or persons in possession, and hereby requests a public hearing before the Code Enforcement Special Magistrate, City of Okeechobee, to hear the following: 1. Violation of City Code Chapter/Section: IPMC Ch 3 Sec 304.1.1(8) and Sec 304.7 2. Location of Viol��tion: 914 NW 2ND STREET, OKEECHOBEE, FL 3. Legal decription: Parcel # 31537350010013200160 4. Respondent(s) name & address: GLORIA RODRIGUEZ; 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643 5. Description of violation; HAVE ALL UTILITIES (POWER AND WATER) DISCONNECTED, REMOVE ALL PERSONAL ITEMS FROM INSII�E TME HOUSE AND OBTAIN A DEMOLITION PERMIT. 6. Date by which violation is to be corrected: 6/21/2019 NOTICE IS HEREBY GIVEN that the alleged violation will be presented in the City Council Chambers, City Hall, 55 SE Third Avenue, Okeechobf:e, Fiorida on the 25th day of June, 2019, at 6:30 p.m. If you have corrected the violation(s) by the time stated above and received notification from the Code Officer that all violations have beei� corrected, you will not be required to appear. Otherwise, you must be present at this hearing to avoid an order being entered solely on the evidence to be presented by the petitioner and a lien being recorded against your property. Violators may be fined up to $250.00 for each day the violation is proven to exist. In cases of a repeat violation, the Special Magistrate may increase the fine up to $500.00 per day. In addition to fines, the amount of the lien may include costs incurred in prosecuting the case pursuant to Section 162.07(2), Florida Statutues and reasonable cost of repairs required to bring the; property into compliance pursuant to Section 162.09(1). You have the right to obtain an attorney if you wish, and the Magistrate will receive testimony and evidence at said PUBLIC HEARING, make firidings of fact as are supported by the evidence, and issue appropriate orders necessary to bring the alleged violation into compliance, including the payment of a fine by the Respondent(s). It is your obligation to insure an accurate record of tfne proceeding is taken for an appeal. Pursuant to Section 162.06 Florida Statutes, you have a responcibility to disclose violations to any potential buyer of the property and notify the Code Enforcement Department of the transfer, with the identity and address of the new owner and copies of the writter� disciosure made to the new owner within five days after the date of the transfer. Failure to make the disclosure creates � rebuttable presumption of fraud. Sale of the property will not ca se this case to be dismissed. DATED THIS ��' day of ��,t-1, �, 2019 � � CODE ENFORCEMENT ,••Fr Ster' 55 SE 3rd Avenue de Enforcement O�cer Okeechobee, Florida 34974 (863) 763-9795 � � -° r ;; a - , ,,��j.� '�' -^i ��:� ,�,;�: ': � �_��i 'r� "t .`��, �C9��C�' �t�'��°�'��"Offi' Code Enforcement for The City� of Okeechobee Notice: Da�te has been changed for Special Magistrate Hearing Please be advised the Special Magistrate hearing scheduled for June 1 l, 2019 is now rescheduled for June 25, 2019 at 6:30 pm. You will need to make every effort to attend this hearing. If you will have difficulty attending the June 25"' hearing, please contact our of�ce at 863-763-9795. Sincerely, Fred Sterling Code Enforcement Officer (863) 763-979_`� 50 S.E. Second ��venue • Okeechobee, Fforida 3�974 �$63/763-552i 0�ax: $fi3/763-7804 CODE ENFORCEPJIENT SPECIAL MAGISTRATE THE CITY OF i�KEECHOBEE, FLORIDA CITY OF OKEECHOBEE Petitioner, -vs- GLORIA RODRIGU'EZ Respondent(s) NOTICE OF VIOLATION / NOTICE OF HEARING CASE NO. 18-00043 Pursuant to Florida Statutes 162, & Chapter 18 Section 18-33 of the Code of Ordinances of the City of Okeechobee, the undersigned Code Officer, being first duly sworn, and with personal knowledge of the facts, hereby alleges the existence of uncorrected violations of the Code of Ordinances and gives notice herein to the landowner or persons in possession, and hereby requests a K�ublic hearing before the Code Enforcement Special Magistrate, City of Okeechobee, to hear the following: • 1. Violation of City Code Chapter/Section: IPMC Ch 3 Sec 304.1.1(8) and Sec 304.7 2. Location of Viola.tion: 914 NW 2ND STREET, OKEECHOBEE, FL 3. Legal decription: Parcel # 31537350010013200160 4. Respondent(s) n�ame & address: GLORIA RODRIGUEZ; 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643 5. Description of vi��lation: SEPTIC SYSTEM PUMPED OUT & FILLED IN, POWER TURNED OFF, PERSONAL ITEMS REMOVED FROM 3TRUCTURE AND DEMOLITION PERMIT OBTAINED FROM CITY BUILDING DEPARTMENT 6. Date by which violation is to be corrected: 5/10/2019 NOTICE IS HEREBY GIVEN that the alleged violation will be presented in the City Council Chambers, City Hall, 55 SE Third Avenue, OkeechobE:e, Florida on the 14th day of May, 2019, at 6:30 p.m. If you have corrected the violation(s) by the time stated above and received notification from the Code Officer that all violations have been corrected, you will not be required to appear. Otherwise, you must be present at this hearing to avoid an order being entered solely on the evidence to be presented by the petitioner and a lien being recorded against your property. Violators may be fined up to $250.00 for each day the violation is proven to exist. In cases of a repeat violation, the Special Magistrate may increase the fine up to $500.00 per day. In addition to fines, the amount of the lien may include costs incurred in prc�secuting the case pursuant to Section 162.07(2), Florida Statutues and reasonable cost of repairs required to bring the: property into compliance pursuant to Section 162.09(1). You have the right to obtain an attorney if you wish, and the Magistrate will receive testim�ny and evidence at said PUBLIC HEARING, make findings of fact as are supported by the evidence, and issue appropriate orders necessary to bring the alleged violation int�� compliance, including the payment of a fine by the Respondent(s). It is your obligation to insure an accurate record of the proceeding is taken for an appeal. Purs.uant to Section 162.06 Florida Statutes, you have a responcibility to disclose violations to any potential buyer of the property and notify 1`he Code Enforcement Department of the transfer, with the identity and address of the new owner and copies of the written disclosure made to the new owner within five days after the date of the transfer. Failure to make the disclosure create�� rebuttable presumption of fraud. Sale of the property will not caus this case to be dismissed. c1 DATED THIS �, day of �, �c J , 2019 � � �.r CODE ENFORCENIENT Fr d Sterl' g 55 SE 3rd Avenue de Enforcement Officer Okeechobee, Florida 34974 (863) 763-9795 CODE ENFORCENIENT SPECIAL MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA CITY OF OKEECHC)BEE Petitioner, -vs- GLORIA RODRIGUI�Z Respondent(s) NOTICE OF VIOLATION / NOTICE OF HEARING CASE NO. 18-00043 Fursuant to Florida 3tatutes 162, & Chapter 18 Section 18-33 of the Code of Ordinances of the City of Okeechobee, the undersigned Code Officer, being first duly sworn, and with personal knowledge of the facts, hereby alleges the existence of uncorrected violations of the Code of Ordinances and gives notice herein to the landowner or persons in possession, and hereby requests a public hearing before the Code Enforcement Special Magistrate, City of Okeechobee, to hear the following: 1. Violation of City Code Chapter/Section: IPMC Ch 3 Sec 304.1.1(8) and Sec 304.7 2. Location of Viola�tion: 914 NW 2ND STREET, OKEECHOBEE, FL 3. Legal decription: Parcel # 31537350010013200160 4. Respondent(s) name & address: GLORIA RODRIGUEZ; 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643 5. Description of violation: ACCORDING TO THE INTERNATIONAL PROPERTY MAINTENANCE CODE THIS STRUCTURE IS UMSAFE DUE TO ROOFING DEFECTS AND INADEQUATE DRAINAGE. 6. Date by which violation is to be corrected: 4/09/2019 NOTICE IS HEREB'Y GIVEN that the alleged violation will be presented in the City Council Chambers, City Hall, 55 SE Third Avenue, Okeechobee, Florida on the 9th day of April, 2019, at 6:30 p.m. If you have corrected the violation(s) by the time stated above and received notification from the Code Officer that all violations have been corrected, you will not be required to appear. Otherwise, you must be present at this hearing to avoid an order being entered solely on the evidence to be presented by the petitioner and a lien being recorded against your �roperty. Violators may be fined up to $250.00 for each day the violation is proven to exist. In cases of a repeat violation, the Special Magistr�ite may increase the fine up to $500.00 per day. In addition to fines, the amount of the lien may include costs incurred in prasecuting the case pursuant to Section 162.07(2), Florida Statutues and reasonable cost of repairs required to bring the property into compliance pursuant to Section 162.09(1). You have the right tc� obtain an attorney if you wish, and the Magistrate will receive testimony and evidence at said PUBLIC HEARING, make findings of fact as are supported by the evidence, and issue appropriate orders necessary to bring the alleged violation inta compliance, including the payment of a fine by the Respondent(s). It is your obligation to insure an accurate record of the proceeding is taken for an appeal. Pursuant to Section 162.06 Florida Statutes, you have a responcibility to disclose violations to any potential buyer of the property and notify the Code Enforcement Department of the transfer, with the identity and address of the new owner and copies of the written, disclosure made to the new owner within five days after the date of the transfer. Failure to make the disclosure creates a rebuttable presumption of fraud. Sale of the property will not cause this case to be dismissed. �� t DATED THIS �."� ' day of �(Cti��Y�'� , 2019 CODE ENFORCEMENT Fred Sterling 55 SE 3rd Avenue Code Enforcement Officer Okeechobee, Florid�� 34974 (863) 763-9795 � ` ` ? ,{ ' s � • e � p � � 19' , i� �;I �II � , I� ' I, � �ii� � II � Complete items 1, 2, and 3. A. Signature � Print your name and address on the reverse X ❑ agent so that we can return the card to you. ❑ Addressee ■ Attach this card to the back of the mailpieCe, B• Received by (Printed Name) C. Date of Delivery or on the front if space permits. 1. Article Addressed to: RAi_lI: RODRIGUEZ PO BpX 53? OK1?ECHUBEE, FL 34973 D. Is delivery address different from item 1? ❑ Yes If YES, enter delivery address below: ❑ No II' �I�I�I I�II I�I I III� � II I I� II I I IIII I��II'll II� 3. Servfce Type ❑ Priority Mail Express� ❑ Adult Signature ❑ Registered MaiIT"' ❑ Adult Signature Restricted Delivery O Registered Mail Restricted ❑ Certified Mall� Delivery 9590 9402 4228 8121 3269 48 ❑ Certified Mail Restricted Delivery ❑ Return Receipt for ❑ Collect on Delivery Merchandise 2. Article Number (Transfer froRi service labelJ ❑ Collect on Delivery Restricted Delivery ❑ Signature ConfirmationTM 7 016 2 710 � � p� 17 2 5 0 3 9 3 ry � Signature Confir ry tion :stricted Delive Restricted Delive � Ps Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Return Receipt � ; � \y. F' k . _ F• �� m �j a^ ��,A��`my �:;� �;; r;r�� f�keechobee , - �;:yQ � . '� �q. �_n � # _q... . � A -v,t ,_ : �r7 , ,;� � y :,j _ , � �bee, Florida 34974-2932 Q' — R ' r�, r,-i -z, .--..; _ 4�; r, I :'.�� . '"_ "` e .�.. .. ; .. �'`Ys`i;�`o"f'`,�`..�,.,- . ul U � � � � � � a J .v ,.,��_ rl Rgt��... c:o� _. �. ��_'�„y "' , mo reo as approR6aie) r, i��u�uuopyj "' __ ❑Recum Roceipi (elecironic) � ❑ �eriitied Mail Aestricted Daiiverr t� �_ [IP.dult Signa.ura Requireo ❑Adult Signature Resfric� n, � �_ i'OSfillBfi: Here J / � � � /j' �' � ` f _ ;,�. f/� % � �� `_ C�,��,_�_:�:��_ :� ��_��E.�_,____-----_ � � �`�-�� '�as�r c �.z.�.:; �4 t ' �� a..� �i r F C ?,�,',�� t '�"`'�^r` �T'^'�"� N " - - :.,_.:�, ��.� ��C.t`u ��.La�x�� hS�: f � _ _ �:';�T ��I_. ..... �:r1�.�L. � i _ ��- .' ` _ . "' °: � � : : 7016 271� 00�0 1725 �393 � ��tt �� :7`` J,' �:� �, . �,= t „ . -:__ _��-�_ � � �,_. . f . ! _., . ,. . .. RAUI, RODRIGUEZ PO BO�i 533 �'�� i �° -,; - ,,. ; ; j,��:: �KEECHOBEE, FL 349"3 a . .m J•: r �_ ,w .t .m ... ... �._ .r ... .-_c . _ .:.. C� . � vz „ic,}.� i'�'�1[:�=.��r'^+.:.s�.��'Fui=.: ' - "' � �e it- : _ �— ' — _-; �i �' ;� • 1 : i .I� � _ - c�i .� _ � �+e iA .':.I.;'l.. �.,.� ,� c'. F.2''.~�. �i:il C';z 1.+ i `" S _ ^! �. - s .� �. : r� � E/ �5 �'-" �_� .. ] ._1 �i 7 .' 1'�� i �:i ...�}.� 3. •15�3 )��:k�-i �3 3�3;3 .5._ '�1� '` ,''n� . . � . . . ,. i � i CODE ENFORCEMENT SPECIAL MAGISTRATE THE CITY OF QKEECHOBEE, FLORIDA CITY OF OKEECHOBEE Petitioner, -vs- GLORIA RODRIGUf=Z Respondent(s) NOTICE OF VIOLATION / NOTICE OF HEARING CASE NO. 18-00043 Pursuant to Florida :itatutes 162, & Chapter 18 Section 18-33 of the Code of Ordinances of the City of Okeechobee, the undersigned Code Officer, being first duly sworn, and with personal knowledge of the facts, hereby alleges the existence of uncorrected violatioris of the Code of Ordinances and gives notice herein to the landowner or persons in possession, and hereby requests a public hearing before the Code Enforcement Special Magistrate, City of Okeechobee, to hear the following: 1. Violation of City C;ode Chapter/Section: IPMC Ch 3 Sec 304.1.1(8) and Sec 304.7 2. Location of Violation: 914 NW 2ND STREET, OKEECHOBEE, FL 3. Legal decription: Parcel # 31537350010013200160 4. Respondent(s) name & address: GLORIA RODRIGUEZ; 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643 5. Description of violation: ACCORDING TO THE INTERNATIONAL PROPERTY MAINTENANCE CODE THIS STRUCTURE IS UNSAFE DUE TO ROOFING DEFECTS AND INADEQUATE DRAINAGE. PLEASE CONTACT THE CITY BUILDING DEPARTMENT AT (863) 763-3372, EXT. 9822 TO APPLY FOR A PERMIT TO EITHER REPAIR THE ROOF OR DEMOLISH THE STRUCTURE. 6. Date by which violation is to be corrected: 3/12/2019 NOTICE IS HEREBY GIVEN that the alleged violation will be presented in the City Council Chambers, City Hall, 55 SE Third Avenue, Okeechobee, Florida on the 12th day of March, 2019, at 6:30 p.m. If you have corrected the violation(s) by the time stated above and received notification from the Code Officer that all violations have been corrected, you will not be required to appear. Otherwise, you must be present at this hearing to avoid an order being entered solely on the evidence to be presented by the petitioner and a lien being recorded against your property. Violators may be fined up to $250.00 for each day the violation is proven to exist. In cases of a repeat violation, the Special Magistrate may increase the fine up to $500.00 per day. In addition to fines, the amount of the lien may include costs incurred in prosecuting the case pursuant to Section 162.07(2), Florida Statutues and reasonable cost of repairs required to bring the property into compliance pursuant to Section 162.09(1). You have the right to obtain an attorney if you wish, and the Magistrate will receive testimony and evidence at said PUBLIC HEARING, make findings of fact as are supported by the evidence, and issue appropriate orders necessary to bring the a!;��ged violation into c;ompliance, including the payment of a fine by the Respondent(s). It is your obligation to insure an accurate record of the� proceeding is taken for an appeal. Pursuant to Section 162.06 Florida Statutes, you have a responcibility to disclose violations to any potential buyer of the property and notify the Code Enforcement Department of the transfer, with the identity and address of the new owner and copies of the written clisclosure made to the new owner within five days after the date of the transfer. Failure to make the disclosure creates a r�buttable presumption of fraud. Sale of the property will not c se this case to be dismissed. DATED THIS �-��day of ��j��,� `�2019 I CODE ENFORCEMEh�T ed Ste mg 55 SE 3rd Avenue Code Enforcement O icer Okeechobee, Florida 34974 (863) 467-1586 � �� _ � I ir.[um Receipt (harcicopy) $ [ � I ioturn Recaipt (eleclronic) $ ❑ Cortifiod Mall Festricted Delivery $ �_Indunsi9natureaequired S � � �dult Signature Restrleted Delivery $ � � , es appropriefe) Postmark � Here , � � ., _ �_ � r '� � Z ��---- � � -----�-z- -------------� ,�1--�---- -- ------------------- ■ Compie:te items 1, 2, and 3. A. Signature ■ Print your name and address on the reverse X�,�,� ��,�� Agent so that we can return the card to you. ❑ Addressee ■ AttaCh ':his Ca1'd to the baCk of the mail leCe, B• Received by (Printed Name) C. te of elivery or on th�e front if space permits. p �� '�'" \��'� � �.�'v-�? "%j�� 'G� Article Addressed to: D. Is delivery address different from item 1? 'u Ye5 If YES, enter delivery address below: ❑ No ULOT�:IA RODRIGULZ c/o R,��UL, RODIZ IGi1E7 PO BOX 53? OKEE?CFiC�J3T�E. I'i� 34973 � �� 3. ServiceType I ❑ Adult Signature �Adult Signature Restricted Delivery Certified Mail� 959 � 9402 4� 28 8121 3268 6.""� ❑ Certitied Mail Restdcted Delivery ❑ Collect on Delivery 2. Aflicle NUmber (Transfer lrom service Iabel) � Collect on Delivery Restricted Delivery -- -- "-`I 7 � 16 2 71 � � 0 0 0 17 2 5 0 4 9 2 I Restricted Delivery ❑ Priority Mail Express� ❑ Registered MailT'^ O Registered Mail Restricted Delivery � Return Receipt for Merchandise � Signature ConfirmationT"' O SignaWre Confirmation Restricted Delivery � PS Form 3f311 , July 2015 PSN 7530-02-000-9053 Domestic Return Receipt USPS TRACKING # 9590 94�2 4228 87,2], 3268 63 Unifed States Postal Service First-Class Mail Postage & Fees Paid USPS Permit No. G-10 • Sender: Please print your name, address, and ZIP+4� in this box• CIiY OF OKEECHOBEE CODE DEPT. 55 S.E. 3rd AVE. �_, ", -' ,,. OK�E��C�Q��,��,3��;�,� , � _ �. l�i��1��1>>111r�1i1,f,i1ll�i,l,�,�lj�'li�ll�11�1t�11j1%/IJjlrl`�� -� ��_ B � I . • � _O , � �Certified Mail Fee � ,f xtra Services & Feas (checkbox, eddi � � Rotum Recelpt (harcicopy) $ _ : � ( ] Raturn Receipt (elecironlc) $ _ -� [ � Carti(ied Mail Restdcted Delivery $_ �� _JAduItSlgnatureRequired $_ � [ J Adult Signature ResMcted Delivary $_ � Postage 'r� �S �� ITotal Postaga and Fees '� i.: % State. � .. r �r-`� . ... Postmark . Hero I � �� f � �l_C�.�_�Q��tl G�� o� P ox No. -- -------------------------------------- ---- --D-+�__�CSc�,�",-�Z.Z--------------- - .�.Ka1pl.: � , '" `.q•,. � 4'i'"'� __rt3, _--_� . ..,� . „� ..,_ 'f�.�'.-. _ oCidf>i�,.i:::; ■ Complete items 1, 2, and 3. ■ Print �/our name and address on the reverse so that we can return the card to you. ■ Attacli this card to the back of the mailpiece, or on the front if space permits. Article Addressed to: GLORIA RODRIGULG c:%o NOI; RODRIGUCZ. 17;2� T�TV�% 21:�"r`' DRIVE EIiGII SPRINGS, FL 32643-6403 I I I I I III'I I I II I I � II I�I (I (I I I I 9��90 9402 4228 8121 3268 56 Article Number (Transfer from service label) 7016 277,0 �0�� 1,725 A. Signature X � � ❑ Agent ��- � �' � � �'l.tt ❑ Addressee B. Received by (Printed Name C. Date of Delivery 1 i. ;" , -6i� f'J ��-LL � Z _�,�, ./ G D. Is delivery address differ�nt from item 1? ❑ Yes If YES, enter delivery address below: p No 3. Service Type ❑ Adult Signature ❑ Adult Signature Restricted Delivery � Certified Mail� ❑ Certified Mail Restricted Delivery ❑ Collect on Delivery ❑ Collect on Delivery Restricted Delivery 0 4 8 5 lestricted Delivery ❑ Priority Mail Express� ❑ Rec�istered MaiITM ❑ Registered Mail Restricted Delivery ❑ Return Recelpt for Merchandise ❑ Signature ConfirmationrM ❑ Signature Confirmation Restricted Deiivery PS Form 3811 , JUIy 2015 PSN 7530-02-000-9053 Domestic Return Receipt USF�S Tlr�, AGK'�M¢,�A` ;' . !.. :':': � ,; l.. � 959� 9402 4228 8121, 3268 56 United State� Postal Service First-Class Mail Postage & Fees Paid USPS Permit No. G-10 ° Sender: Please print your name, address, and ZIP+4� in this box° CIiY OF OK�ECHOBEE CO�DE DEPT. 55 S.E. 3rd AVE. OF�C�ECF#0�31FE, FL �49'�4 RECEiv� �liii�i��rffllii�i�}j��,ii'i'iiiN{iiili�[i�}n�li�}{'#ii�"ii�� a Services R Fees (cneck box, edc �etum Receipt (harUcopy) $ . P.etum Receipt (electmnic) $ CertRied Mall Restricted Delivery $ � I ��dult Signature Requlred 5 i i �%�dult SlgnaWre Restricted Dellvery $ I'nsiage es appmpnate) Poslmark I-lere �.��C' �/ ^f��----- State, ZIP+4' -- ---- ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: RAU1� RODRIGUF,7 ►'O I3C�X 5"�3 OKEECH(:3EL, l� L 34�7 � I IIIII I'I III�IIII �II III IIIII I�II 9590 9402 4228 8121 3267 02 2. Article Number (Transfer from service label) 7171,6 2710 �� 7,725 ---___. _ _,..�..�.. -__--- PS Form 381 1, July 2015 PSN 7530-02-000-9053 A. Signature � ti / j � / /j ❑ Agent X -.� L,�L_ � ^-�� Addressee B. Received(b'�(Printed;,Name) C. D^a�te eli ry � 4,v..� �Y��'S � V. .�% � D. Is delivery address differen rom item 1? ❑ Yes If YES, enter delivery address below: ❑ No 3. Service Type ❑ Adult Signature ❑ Adult Signature Restricted Delivery Certified MaiIOO ❑ Certified Mail Restricted Delivery ❑ Collect on Delivery ❑ Collect on Delivery Restricted Delivery Q[� Q 7 9estricted Delivery ❑ Priority Mail Express� ❑ Registered MaiITM ❑ Fegistered Mail Restricted, Delivery ❑ Retum Receipt for Merchandise O Signature ConfirmationT^^ � SignatUre Confirmation Restricted Delivery Domestic Return Receipt v�s�� °��o�a�� •�nm paE ��s ss 'ld3a J�03 3380H�3��10 �O A.�I� .xoq siu; ui �„ti+dlZ Pue `ssaapp� 'aweu ano�C }uud asea�d :aapuag o 06-J 'oN ;iwaad SdSfl pied saa� �g afe}sod �ieW sse��-�sn� �3� a�inaag �e�sod sa��;S pa�!�fl Z� Z92E '[2'CQ Q22h 20h6 0656 # �rvi��da.�. sdsn - `�. F k �• � n °isisn a City of Okeechobee 55 3.E. Third Avenue • Okeechobee, Florida 34974-2932 _..: _...._..�a�-.� ___._...� . .__ .��- ��:�ti..�.: �:�-'��'u.o-' ��.�' r��r_�:: ,. `�`�::'=.. -�-_,-.•_-- . _ %�i�.�:�At;'c- ` ; . ... 7�16 27Z� �� 7,725 �478 GLt�RI.A RUDRIGL'F,Z c!o NOE RODItIGUEZ 17324 NW 213TI� DRIVr HIGH SPRINGS,I�I, .i2643-6403 .. � ��,��{lI V' A 'i t'.J .. � ' r 1 l� ?. .}3�� , � x. _ �. i�' � :a ,i':i a.. L� 3.. , �l A: •- .� "' , � .�,. �`. ��' r'>^ ° ��.°f °=4 1 :.. '� �" _.. `�3f - . '"M7 : �,9` �.. "Y �• r .iii! ��1r�� fi �,� 21!if �: f � i: li:l?f�' i�� : i � S .�Ir"�t.".:=.j�.:f.:;:..:.r.;,,i:»+:+�F:� �j� ..' ' " .. ...._._.,.. .. .... . . ,. _. .' ' '.... .: .. .._. _. ,. . �3. �" " �� (nN i �� ,,} '�`' o . �. � "�`�rs��*�"'' � t��r,�'��C"��i. � 6 a a� .�u,. t�'�;' �.� ... . �...v _ '.� ',_�.'S . �:�-. c�.9 t _ _�_. ". . . "" i I ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: GLOR.IA KO�KIGUEZ c10 ?vTOE RUDRIGUF7 ' ; ;'324 NVv �13�''`� DRIVE 1 {IGH SPRI?�lG�, �L 32643-6�03 A. Signature X B. Received by (Pnnted Name) � �,� ��_ � ,..4 " � .. - . . r ✓ �� `� ��. .�'., .-. n,�,;. , � : :: � - �1 �.�i ��''�:: -i, e : . ... .._._ - ,r?r"',T— ,:, , .. , , �,a :;�:...�1 � � � �p� � 6� 9� v� d ti:A r"' `rti 1'`"1""� L,/ - ? _� %. ::_� _. . < <- . .. �-- �, '. ,.. �'Y' ,�, . �.s . :< r. i _ : , � : yI _ _. _ .+rt L^ � �.. . % . .. a.: w. .... . ..n . �ai� : .. . � :"t �. .v '9 _5 � x; : F ��zi f( «SY�" .:',�. . . ��•' � �� S� . � y ks' ' � "`. Y � � s � ��-' - ��''rl', t�_ 7'{'k,'4 , ?� �`� � d9 � �� s � � r `� �{ � �p � � r� � r: rear �� v ❑ Agent � _ ❑ Addressee .� � � �.��i�� r,��;�a.�sr.�:eK°.�'��'i9�1��5'�-- �'.�rr�.,«°�. w � ' C. Date of Delivery �� . I D. Is delivery address different from item 1? ❑ Yes if YES, enter delivery address below: ❑ No NC.:ertlfied Niail Fee � [`- ��; � E;tra SENiCes & Fees (checkt�o:, add res as approPrizte) � ❑ Retum Reoeipt (haNcopy) :a ._r_ � j ❑ Retum Focaip4 (electronic) __ � �❑ C�rtined Mail ftestricted Calive,y �_ _ 0 i �=� ,dult Signature Required $ O!❑ Adult Signature HesVicted Delivery $ � PoStage ; � ,�. - . - — �. ,r,,rai Postage and Feas ff 3. Service Type ❑ Priority Mail ExpressO RJ j, I I I' I� I �' I I�� I� I I� � I I I I� I I I I II I �I� II I I��I� 0 Adult Signature ❑ Registered MaiITM ❑ Aduit Signature Restricted Dellvery ❑ Registered Mail Restricted „p Certified Ma(f� Delivery � 9590 9402 4228 8121 3266 96 Certified Mail Restricted Dei'rvary ❑ Retum Receipt for p O Collect on Delivery Merchandise �.� ❑ Collect on Delivery Restricted Delivery � Signature ConfirmationT'" 2. Article Number (Transler from service Iabe1J n �..�,,.� nna;� ❑ Signature Coniirrnation 7 01 E, 2 710 � � � � 17 2 5 � 4 7 8 dl Restricted �elivery Restricted Delivery � � PS Form 3811, July 2015 PSN 7530-02-000-9053 Domestic Return Receipt ,� � � � � , �� `anclApE N �r ��ox N �� 1 -----------------�-•---�---------------- itate, ZIP+4� . �� .:,,_ � �, .,,• 1'osimark �lere ��J � � ; _ - i7 1��d,� �?0�'1� ��""r. ` '� {�� <,'.v� �> _ � .x .►��"�g� -f'�C�r � r: c ' � ' t� �' <. . r � �' � i �,� _ .. _ _; � , f� � - -- � ,_ ..a t�. d`�. , ''t, — y _ �— � � ` l� J h�\ , . . T�i : ;�Y� +u: -•— . " r—i ��,.,�• :+�' � � . . ' !�► ��`"'�'V �►-�� .;�+y_:: . _ _ . . -- � ._ - ." " . .. � - - - - ,�.�, s . � I �4 x • .,r� _ ; �'i.,_y � '4 i � 51� ' . .. � ' . i' . r' � _ . \ \\' � a _�, ,,s _ � fr y . . - F «� v `�` c - _ ' • . ,. . . y � � .. . � t ' M ` .. : ' 4 � j U i'� � ` . . '— '� ys � r � �,,., '._ ��. � r. _ ro. �- ��`�,w� ,�'� .�-'�'�+�...;; .� - - _ � -� � r �` , � + : _� '-�A� . ..� � R �� .r. .i � . . � < _��7�fr- . r � _ ��s.t . A's �� c ,yP � 't�v X z . � _ �,�. r� .t�'. �� . _ . _ i . .,`.._. �r: � -- • . . . .�..._,�, .., �.� �. . . . . . . . . _ ._ n . � -y. . . , � . � � y ' ,. , ,... ..i•. �� ,. �V 1..at y'r�$ '�3K�'A�x, e � f�'"�.,a" a'� rta �r�aa�,+�. 5� i � /� t M7 1 TM N f . }� t f.Y+,� y5 � � �F�UEj� �O��i{A�1S��I,��I��F R'M �1�� P I S.�I+ � � {R�.a�j �� 1 kk + r ��C�� '�TI��ED;MAIL°�RECE�PT�,�;,�, °�`�`��;�s� �yi A� Dom�t►c- aifi On � �. ` `` �`� ' � ��'` ` ° s_. ��? �, .� ly��.��k��.��:��:� „f F,or; cJeli,v,ery 1nf,ormati �'�visi� ourrv?ie6site�at�v�,w� usps�co'rn��n;� � - u'1 f1J C�- r�i O O O O � e-� [�- r1J � � O [�- ; a Camplete items ti; 2, and 3. �� Print your name and.address on the reverse so thafi we can. r�u�� tlie card to you, ■ Attach this card fo the back of the mailpfece, or on the front tf space permits. GLORI�, RODRIGUEZ c; o NOE RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 � i : _ �' X .:' c-�'l�(�- B. R ce( ed�y (Prinfed NameJ D. Is delivery address different from Item 1 ❑ If YES, enter delivery address below: p of 3. Servlce Type O Pdority Mell Express� ' II I'I�I'I I'II I�I I II�� I II I I' II I I I�II I I I�II I� III �,Adult Signature Reshlcted Dellve � Reglstered Mallr'" ' 9590 9402 4228 8121 3270 20 Certlfled Mall� ry � Re�istered Mail Restdcted' �` Delivery CertlFled Mail ResVicted pel�very ❑ Retum Recelpt for ❑ Callect on DelWery Merohandise - 2: Article Number (Transfer lrom selylce label O Collect on Delivery Restricted Delivery ❑ S(gnature Conflrmatlon*�+ . 7 � 16 2 71 � 0 � � Cl 17 2 5 O��L' 4 Istricted DelNery O Restrict d Dellveryatlon „---- ; PS Form :3811 JUIy 2015 PSN Z530-02-000-9053 ' � ' " Domestfc Return Recelpt CODE ENFORCEMENT SPECIAL MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA CITY OF OKEECHOBEE Petitioner, -vs- GLORIA RODRIGUEZ Respondent(s) NOTICE OF VIOLATION / NOTICE OF HEARING CASE NO. 18-00043 Pursuant to Florida Statutes 162, & Chapter 18 Section 18-33 of the Code of Ordinances of the City of Okeechobee, the undersigned Code Officer, being first duly sworn, and with personal knowledge of the facts, hereby alleges the existence of uncorrected violations of the Code of Ordinances and gives notice herein to the landowner or persons in possession, and hereby requests a public hearing before the Code Enforcement Special Magistrate, City of Okeechobee, to hear the following: 1. Violation of City Code Chapter/Section: IPMC Ch 3 Sec 304.1.1(8) and Sec 304.7 2. Location of Violation: 914 NW 2ND STREET, OKEECHOBEE, FL 3. Legai decription: Parcei # 31537350010013200160 4. Respondent(s) name & address: GLORIA RODRIGUEZ; 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643 5. Description of violation: ACCORDING TO THE INTERNATIONAL PROPERI"Y MAINTENANCE CODE THIS STRUCTURE IS UNSAFE DUE TO ROOFING DEFECTS AND INADEQUATE DRAINAGE. PLEASE CONTACT THE CITY BUILDING DEPARTMENT AT (863) 763-3372, EXT. 9822 TO DISCUSS THIS MATTER. 6. Date by which violation is to be corrected: 2/01/2019 NOTICE IS HEREBY GIVEN that the alleged violation will be presented in the City Council Chambers, City Hall, 55 SE Third Avenue, Okeechobee, Florida on the 12th day of February, 2019, at 6:30 p.m. If you have corrected the violation(s) by the time stated above and recelved notification from the Code Officer that all violations have been corrected, you will not be required to appear. Otherwise, you must be present at this hearing to avoid an order being entered solely on the evidence to be presented by the petitioner and a lien being recorded against your property. Violators may be fined up to $250.00 for each day the violation is proven to exist. In cases of a repeat violation, the Special Magistrate may increase the fine up to $500.00 per day. In addition to fines, the amount of the lien may include costs incurred in prosecuting the case pursuant to Section 162.07(2), Florida Statutues and reasonable cost of repairs required to bring the property into compliance pursuant to Section 162.09(1). You have the right to obtain an attomey if you wish, and the Magistrate wiil receive testimony and evidence at said PUBLIC HEARING, make findings of fact as are supported by the evidence, and issue appropriate orders necessary to bring the alleged violation into compliance, including the payment of a fine by the Respondent(s). It is your obligation to insure an accurate record of the proceeding is taken for an appeal. Pursuant to Section 162.06 Florida Statutes, you have a responcibility to disclose violations to any potential buyer of the property and notify the Code Enforcement Department of the transfer, with the identity and address of the new owner and copies of the written disclosure made to the new owner within five days after the date of the transfer. Failure to make the disclosure creates a rebuttable presumption of fraud. Sale of the property will not cau e this case to be dismissed. DATED THIS 1�day of��ji1(�C+�(' �j , 2019 �%.{�„� i U �� CODE ENFORCEMENT �d Ste mg 55 SE 3rd Avenue Code Enforcement O i r Okeechobee, Florida 34974 (863) 467-1586 C �-� a CJ �.e�c�.obee � Co�.e En.forcemevi.t CODE ENFORCEMENT BOARD CASE # 18-00043 I�i�TICE OF VIOLATlON 1 Q/23/2t718 GLORiA RODRlGUEZ 17324 NW 213TH DR1VE HIGH SPRlNGS, FL 32643 RE: LOTS: 17 & E 1/2 �F 16 BLK: 132 PARCEL: 31537350Q10013200160 i�, violafion of local codes involving your property within the City of Okeechabee has been ciied. PROPERTY LOCATION: 914 NW 2Nb STREET, �KEECH�BEE, FL NATURE OF VIOlATION: f PMC Ch 3 Sec 304.1.1(8) and Sec 304.7 COFZRECTIVE ACTfON REQUIRED: ACCORDfNG 70 TNE INTERNATIONAL PR�PERTY MAINTENANCE COQE TH1S STRUCTURE IS UNSAFE DUE TO ROQFING DEFECTS AND INAbEQUATE DRAINAGE. PLEASE CONTACT THE CITY BUILDING DEPARTMENT AT (863) 763-3372, EXT. 9822 TO DISCUSS THIS MATTER. The corrective action outlined should be taken within ten (10) days from the date of receipt of this letter and the Code Enforcement Officer contacted to verify compiiance. Failure to take corrective action or contaci the Code Enforcemenf Officer within this time frame will subject you to appear af a hearing set before the Code Enforcement Board. In addition, a fifty do4lar administrative fee may be charged if the violaion is not corrected prio� to mailing the notice to appear before the Code Enforcement Board. tf the violation is corrected then recurs, the case shall be presented to fhe Code Enforcement Board even if the violafion has been corrected prior fo the hearing. if you.have any questions regarding this notice, piease contact our office at 863-467-1586. Sincerely, re Sterling Code Enforcement Officer (863} 467-1586 55 S.E. Third Avenue • Okeechobee, Florida 34974-2932 •(863) 467-1586 • Fax: (863) 763-4489 { ,�e A �. �'� �n�le V'�olatic�n /Nati�ce i� Ap��ar �t�port Uate of i��ira�i�n: Properl,y Ownet�: Coa�taCt �� 0 �� 'G �o� � �.3 t1�� E �� '��%% �.,�� „ D�te Contacted: �ow� �Cantacted: Locatian nf lt�ai�ing Address: % �� C1�= �r,X�r'21�,r�s� �-/ % %� � ��. /�G.. LOt S : � � ��.%�,3�- fc�►� { ) �% �2 �� tock: �3�� SeGiio�3. C_"� t�n(,�%,,��, �-� Farcel # �-- �S � � ��35 -� c�/� -f.�l3,z. .. C�l,lG V'�o�at��►n: #1 ��sabl�cl'V'e��cle #2r_____Untended Vegetatio�x #3 G�neral Cleaning #4 �'ublic Na�sa�nce �5 1r Suilcii�ug Departme�t #6 �'ublic'VV'orks �iotes About `V'�nlatiosn: �"��'hG �.3�'�, �•C�'.� i.��oss��'�C�u�lo,�a.�� 3c�l.'7.� �,f�,�� -�� -_ � N��ice af Violation Mai�ed: �� Received � �Iand Delivered Posted Noti�c+e to Ap�ear �atied: /� R�ce�►ed S�and Delirvexed Posted ��uspected Fxnd�ng N'otes: �"�� ' `�. Da�ie �n Comp�iance: Pro-Act�ve � R,eact�ve ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. Article Addressed to: GL(�RIA RODRIGUFZ c/o NOL-; RODRIC'1trLZ 17324 NW 2.13�"` DR]VE. H1GH SPRINGS, F_L 32643-(,403 I I' I' I' I I I I I I I I I I I I I I( I I' I I I 9590 9402 4228 8721 3272 80 A. Signature 1!,, � �" ._ ❑ gerit Xf ` �. �--G�"�G" Addressee B. Received b(Pr�ted,Na , e) C. Date of Delivery �l� � ,c.��r� ��L > � zs' D. Is delivery address differe t from item 1? ❑ Yes If YES, enter delivery address below: ❑ No 3. Service Type ❑ Adult Signature O Adult Signature Restricted Delivery �Certified Mail� ❑ Certified Mail Restricted De�ivery ❑ Collect on Delivery ❑ Priority Mail Express� ❑ Registered MaiIT"' ❑ Re�istered Mail Restricted: Dehvery ❑ Retum Receipt for Merchandise 2. ArtiCle Number (Transfer from ServiCe l3bell I � Collect on Delivery Restricted Delivery � Signature ConfirmationT^' ❑ Signature Confirmation 7 � 1, 6 2 710 0 0 0 Cl 1, 7 2 5 ��L 0 1 ;stricted Delivery Restricted Delivery — - �, PS Form 3811 , JUIy 2015 PSN 7530-02-000-9053 Domestic Return Receipt USPS lR�kf��N� �;: � w �:: ; ;. ; j . 9590 9402 4228 8],21 3272 80 United States Postai Service First-Class Mail Postage & Fees Paid USPS Permit No. G-10 • Sender: Please print your riame, �ddress, and ZIP+4"' in this box• CI�Y OF OKEECHOBEE CODE DEPT. 55 S.E. 3rd AVE. QF'C��CFiOBE�, �L 34974 RECEIV � ucl Z 9 201� ii'1)11fill'11��'jfl„�1,i1)ili��,Jjr,�ii�,�,�1�1��,,,�1�1��'",i1 ��c �� .��, c .-'J L� This Instrument Prepared and Return to: Colin M. Cameron, Esq., P.A. 200 N. E. Fourth Avenue Okeechobee, FL 34972 Parcel No. 3-15-37-35-0010-01320-0160 F- _ � hJ �...� r� ?�_� 1 1 �_� i�1 � �� ,,� � �b�4 �K � ��_��'� �.� F•�"., 1� ��'r4r SHARON ROBERTSl7hl, GLEkY, OF f•I�(:UIT GOUfiT OKEEGFiOQEE C:OU�tTY� FLDRIDf� kECOfiQED ii7/?�1/?i_i11 ii2:53:5�, f'M AMT iii,iiii RECOfiDING fEES �18.5ii DEEU DOC: ��,7�i FiEC:ORDED BY R f'nrr i sh F'95 1i144 - 1��45i (2p95) THIS WARRANTY DEED, made the � day of July, 2011 by GLORIA RODRIGLTEZ, a single woman, herein named the Grantor, to GLORIA RODRIGUEZ, a single woman, RAUL RODRIGUEZ, a single man, and NOE RODRIGUEZ, a married man, as joint tenants with right of survivarship, who�e post office address is Post Office Box 533, Okeechobee, FL 34973-0533, hereinafter calIed the Grantees. WI'I`NESSETH, That the Grantor, for and in consideration of the sum of $10.00 and other valuable considerations, receipt whereof is hereby acknowledged, hereby grants, bargains, sells, aliens, remises, releases, conveys arfd confirms unto the Grantees all that certain land, situate in Okeechobee County, State of Florida, viz: Lot 17 and the East %2 of Lot I6, Block 132, Town of Okeechobee, according to the plat thereQf recorded in Plat Book 2, page 17, Public Records of Okeechobee County, Florida Subject to all restrictions, limitations and covenants nuining with the title to the property. Subject property is the homestead of the Grantor. TOGETHER, with all the tenernents, hereditaments and appurtenances thereto belonging or in anywise appertaining. TO HAVE AND TO HOLD, the same in fee simple fQrever. AND the grantor hereby covenants with said grantee that the grantor is lawfully seized of said land in fee simple; that the grantor has good right and lawful authority to sell and convey said land, and � hereby warrants the title to said land and will defend the same against the lawful claims of all persons whomsoever; and that said land is free of all encumbrances; except taxes accruing subsequent to December 31, 2010. IN WITNESS WHEREOF, the said Grantor has hereunto set her hand and seal the day and year first above written. Signed, sealed and delivered in the presence of: e.r-- Wi e Signature �Iv�-+�.. �\ \ So n Witness Printed Name , � � GLC3RIA RODRIGUEZ Post Office Box 533 Okeechobee, FL 34973-0533 Book703/Page1044 CFN#2011007062 Page 1 of 2 � �,�..�a � , q►�...�.D Witness Signature �-�� A�.na /� Witness Printed Name STATE OF FLORIDA COUNTY OF OKEECHOBEE I HEREBY CERTIFY that on this day, before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared GLORIA RODRIGUEZ, known to me to be the persons described in and who executed the foregoing instrument, who acknowledged before me that she executed the same. U Said person(s) is/are personally known to me. (,� Said person s) provided the following type of identification: Flor : d2 Z'-.a CR�'al � WITNESS my hand and official seal in the County and State last aforesaid this I'Q day of Ju�y, 201 l, �MY'riy�� PAMELLA S. ARNOID �� MY COMMI6SION � DD T10570 EXPIREB: Sept6mber 3, 20t S �� BorKNd ihiu Noury PubNc UndMvrNen �� ."�,.�._� Signature of Notary y�,�� s. ,4 �,�� . Print Notary Narne My commission expires: ;� �' � � !� . I hereby certify that I have prepared this inst�rument from information given to me by th� parties hereto. I do not guarantee either marketability of title or accuracy of desaription or quantity of land described as I did not examine the title to the property involved. � � Book703/Page1045 CFN#2011007062 Page 2 of 2 : Okeechobee County Property Appraiser - Map Printed on 3/1/2018 9:23:46 AM Page 1 of 1 � 1 � ��_�� : n � c� � L�� C�� 1�� . http://www.okeechobeepa.com/GISvl/Print Map.asp?pjbojdcfejajpldonlchggpkoempnjc... 03/O1/2018 This information, updated: 2/16/2018, was derived from data which was compiled by the Okeechobee County Property Appraiser's Office solely for the governmental purpose of property assessment. This information should not be relied upon by anyone as a determination of the ownership of property or market value. No warranties, expressed or implied, are provided for the accuracy of the data herein, iYs use, or iYs interpretation. Although it is periodically updated, this information may not reflect the data currently on file in the Property Appraiser's office. The assessed values are NOT certified values and therefore are subject to change before being finalized for ad valorem assessment purposes. OKEECHOBEE COUNTY CLERK OF COURT OFFICIAL DOCUMENTS Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM FORM 1.997. CIVIL COVER SHEET The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant to section 25.075, Florida Statutes. (See instructions for completion.) IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, II. AMOUNT OF CLAIM Please indicate the estimated amount of the claim, rounded to the nearest dollar. $ 16,000.00 III. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the most descriptive label is a subcategory (is indented under a broader category), place an x on both the main category and subcategory lines. CIRCUIT CIVIL Condominium Contracts and indebtedness Eminent domain Auto negligence Negligence —other Business governance Business torts Environmental/Toxic tort Third party indemnification Construction defect Mass tort Negligent security Nursing home negligence Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM Premises liability —commercial Premises liability —residential Products liability Real property/Mortgage foreclosure Commercial foreclosure Homestead residential foreclosure Non -homestead residential foreclosure Other real property actions Professional malpractice Malpractice —business Malpractice —medical Malpractice —other professional Other Antitrust/Trade regulation Business transactions Constitutional challenge —statute or ordinance Constitutional challenge —proposed amendment Corporate trusts Discrimination —employment or other Insurance claims Intellectual property Libel/Slander Shareholder derivative action Securities litigation Trade secrets Trust litigation COUNTY CIVIL Civil Rep levins Evictions xx Other civil (non -monetary) — Municipal Lien Foreclosure IV. REMEDIES SOUGHT (check all that apply): xx Monetary; Nonmonetary declaratory or injunctive relief; Punitive V. NUMBER OF CAUSES OF ACTION: [ 1 ] (Specify) Foreclosure VI. IS THIS CASE A CLASS ACTION LAWSUIT? yes xx no VII. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? xx no yes If "yes," list all related cases by name, case number, and court. VIIL IS JURY TRIAL DEMANDED IN COMPLAINT? yes xx no I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. DATE: November 2, 2020 Signature of Attorney or Party initiating action: /s/ R, =mow r`rf Doc No: 97811 Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, Plaintiff, ►►PA GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, COMPLAINT CASE NO.: COMES NOW, Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff or "City"), by and through undersigned counsel, and brings this action for foreclosure against the Defendants, GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ (collectively "Defendants") and in support thereof states: Venue and Jurisdiction 1. This is an action to foreclosure a lien on the Defendants' real property located within Okeechobee County, Florida. 2. This Court has original jurisdiction over this action because the City's lien and related damages do not exceed the sum of $30,000 exclusive of costs. 3. Venue is proper in the Nineteenth Judicial Circuit because the property in question is located in Okeechobee County, more specifically, Okeechobee, Florida. 3. The Defendants' own real property located at 914 NW 2nd Street, Okeechobee, Florida 32643-6403 and legally described as follows: 4t a) Cn U a� a� 0 U a) a) 0 LL CU U 0 L U a) W Lot 17 and the East "% of Lot 16, Block 132, Town of Okeechobee, according to the plat thereof recorded in Plat Book 2, page 17, Public Records of Okeechobee County, Florida. Subject to all restrictions, limitations and covenants running with the title to the property. Subject property is the homestead of the Grantor. ("Property"). A true and correct copy of the Warranty Deed is attached hereto as Exhibit "A" and incorporated by reference herein. 4. The Property is not homestead property and not otherwise exempt under Article X, Section 4(a) of the Florida Constitution. A true and correct copy of the applicable 2019 Notice of Ad Valorem Taxes & Non -Ad Valorum Assessments is attached hereto as Exhibit "B" and incorporated by reference herein. 5. Pursuant to Florida Statute Chapter 162, the City has the right and obligation to enforce its Codes and Ordinances within its boundaries and has the authority to foreclose applicable liens stemming therefrom. General Allegations 6. By way of background, on or about October 23, 2018, the City sent out a Notice of Violation to the Defendants relative to the Property's unsafe roofing and inadequate drainage. The matter was eventually referred to the Code Enforcement Board in matter number 18-043. 7. Thereafter another Notice of Violation along with a Notice of Hearing before the Code Enforcement Board dated January 18, 2019 was sent to the Defendants via Certified Mail with Return Receipt Requested. Noe Rodriguez signed the Return Receipt on January 22, 2019. 8. The Special Magistrate conducted a hearing on June 25, 2019 and subsequently entered a Lien/Order imposing a fine of $25.00 per day until the violations were correct. 9. The Lien/Order is recorded in Book 828, Page 1250 of the Official Records of Okeechobee County, Florida. A true and correct copy of the Lien/Order is attached hereto as Exhibit "C" and incorporated by reference herein. 10. By way of letter dated October 17, 2019, the Defendants were advised that the daily fires of $25.00 had accrued for over 90 days and that this could result in foreclosure. 11. All conditions precedent for bringing this action have occurred or been performed. Count I — Foreclosure 12. The City realleges paragraphs 1 through 11 as if fully set forth herein. 13. Pursuant to Florida Statutes Section 162.09(3), if a valid lien remains for a period of 90 days and does not otherwise come into compliance, the City may elect to file a foreclose the lien. 14. As of the 90" day, and at all times since, the said lien has not been satisfied and the Property has not come into compliance with the City's Code of Ordinances. 15. In addition to the various mailings, the City has posted notice(s) of lien on the Property itself A true and correct copy of photographs of the posted Notices are attached hereto as Exhibit "D" and incorporated by reference herein. 16. Through September 30, 2020, the Defendants owe the City $11,575.00 plus attorney's fees and costs. Additionally, the fine continues to accrue at $25.00 daily thereafter until entry of the judgment of foreclosure by this Court. 17. The City believes that there may be additional persons who may be interested in the Property, but after a diligent search and inquiry remain unknown to the City. 18. The unknown parties may claim as heirs, devisees, grantees, assignees, lienors, creditors, trustees, or other claimants by, through, under or against the Defendants herein, andtherefore all of the said unknown parties are made defendants to this action. 19. There may be other unknown parties having or claiming to have some right, title or interest in the subject matter of this action, but whose names after diligent search and inquiry are unknown to the City. Diligent search and inquiry has been made to discover the names and residences of any unknown defendants, but their ages are unknown, their residences are unknown, and the City does not know, by, through, or under or against whom they may claim, nor what right, title or interest they may claim in the Property. X The City has expended, and will expend during the pendency of this action, certain necessary costs and shall seek reimbursement of same. 21, Further, the City has retained the undersigned counsel as its attorney in this action and has agreed to pay him a reasonable fee for said services. The said fees are an additional indebtedness authorized by Florida Statutes Chapter 162. WHEREFORE, the City respectfully requests that (a) this Court enter a judgment of foreclosure, ward the accrued lien(s), e*-ises and costs, including attorney'-acpes and costs, .90 PV plus interest to the City; (b) if the said sum is not paid within a time set forth by the Court,, the City requests that the Property be sold at auction to satisfy the City's claim; (c) if the proceeds of the foreclosure sale are insufficient to pay the City's claim, that a deficiency judgment be entered for the sums remaining unpaid against the Defendants herein; and (d) such other relief as this Honorable Court deems just and prpper. November 2, 2020 1 Respeettiffly submitted, NASON, YEAGER, GERSON, HAIL RIS & FUMERO, P.A. 750 Park- of Commerce Blvd., Sit ite 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-71.16 E-mail: ghyden@nasonyeager.com, Attorneys for the Plaintiff Florida Bar No.: 50839 I-11-E NUN 2011007062 OR BK 0070a PG 1044 SHARON ROBERTSONY CLERK OF CIRCUIT COURT OKEECHOBEE COUNTY: FLORIDA RECORDED 07/20/2011 02l P11 ANT 10.00 This Instrument Prepared RECORDING FEES $18.50 DEED DOC $070 and Return to: RECORDED B. Y R, Pull Pos 1044 1045; Upos) Colin M. Cameron, Esq., P.A. 200 N. E. Fourth Avenue Okeechobee, FL 34972 Parcel No, 3-15-37-35-0010-01320-0160 THIS WARRA NTY DEED, made the ff day of July, 2011 by GLORIA RODRIGUEZ, a single woman, herein named the Grantor, to GLORIA RODRIGUEZ, a single woman, RAUL RODRIGUEZ, a single man, and NOE RODRIGUEZ, a married man, as joint tenants with right of survivorship, whose post office address is Post Office Box 533, Okeechobee, FL 34973-0533, hereinafter called the Grantees. ��rcof is hereby acknowledged, hereby grail bargains, Sells, aliens, County, State oorl viz. Lot 17 and the East V2 ofa i s Town of0keechoboo, accordin4 to the plat thereofrecorded in Plat B le 17, Public Records of0keechobee County, Florida Subject to all restrictions, limitations and covenants ninning with the title to the property. Subject property is the homestead of the Grantor. TOGETHER, with all the tenemetits, hereditaments and appurtenances thereto belonging or in anywise appertaining. NO MIM V, MMM a T "K - Mr 717 .5vM 0-V•77071-MM41-5:45-i- hereby warrants the title to said land and will defend the same against the lawful claims of all persons whomsoever; and that said land is free of all encumbrances,, except taxes accruing subsequent to December 31,2010. VM' ! aantor has hereunto set her hand and sea] the day and year first above written. Witness Signature 1 R4 c JJ I, A L#ftJ1fiN,#VjV1JL$JAHR iLO - 4. ilOCOMI"Ir4mr-H that sho oxotuted the saine. (—) Said person(0) is/are personally known to nm provided the following typo -of identl fivation; nig .,a% WITNESS my ha I seal in the County am State last aforesaid this A day of July, 2011, . . . . . . . . . . 041MI, Signature of Notary Print Notary Nara e My commission expires: 11111 11 101411011 WEIIIIIIIIIII Celeste Watford - Okeechobee County Tax Collector ht4)s //www,okeecliobeecoul tytaxcollectaz;com/Pi,opertyil I'axBi1... Notice Of AD Valorem Taxes &lion -AD Valorem Assessments Kilt # R 3000300 2019 R 3-15-37- 5-0010-01320-0160 REAL ESTATETax/Notice Receipt For OKEIECHOBEE County AD VALOREM TAXES RODRIGUEZ GLORIA, ETAL. TAXING AUTHORITY M&LLAGE RATi __. ._ TAX AMOUNT C/t7. NOE RODRIQUEZ 17324 NW 2 DR C4UNrY ,00000000 Ser9t34iL•RtEv.:,.,_...,_,....�„_........�,. .Oa303900 ��134,90 a71.Q9..ixl` ,3TH SPRINGS, l"t..: 32643 - 60 SCM0:0L•015G .00224600 s11♦43 GITY•4NCCEGHOffE1: ,00160180 t32.94 0.258 ACRES SOUTH FL._WAT t4GMNT .000279`0 $4.08 CITY OF OKEE.CHOBEE CH"oRRENs G[iUidC1L .00O36OD0.:, LOT 17 a E 1/2 OF LOT 16 TOTAL AD-VALOREM3 $396.75 BLOCK 132: NON -AD VALOREM ASSESSMENTS TAXING AUTO OR" � iAX Ah%3UMT FAIR MKT VALUE $ d;�527,Qt1 D95T 50 Ascot EMS A�.SGSSMENTt103,53 Astnt GAARN3E ASMT C1.$T.37,96 1S5SE5.5 ¢3.7,488.00:. 0X0A4PT.YALDE. $Q.oQ TOTAL NOWADVALOREW $341.40 TAXABLE VALUE $17,400.00 COMBINED TAXES St ASMTSI $730.24 D15Cr UMTc $0.00 ** PAID %:•.* UNPAID BALANCE. $0.00 Last Payment-, 03131/2020Receipt 9833926 Number. Exemptions: Amount Discount $738.24 �t3'0 Collected: Amount:: Property Address: 914 NW 2 DST OKEECHOBEE 34974 Tax Roll Property Summary Parcel Roll Type Year Original Gross Tax €lttainot Assessments hate Paid Amount Paid Total Unpaid 31537354010913200160 R 2019 $396,76 $34IA9 3/31/2020 3730.24 $0,00 31537350040013200160 lk 2018 $374A7 633315 3/31/2020 $902,75 '$0.00 31537350010013200f$O.R 2017 4334,99 $31236 3/27/2GIO $647.15' $0,00 3153735001OD13200160 R. 2016 4320.7$. $310A4 3/31pou 463138 MOB 31537350010013200160 R 2015 $675.98. $304.20 3131/2017 $1,279.10 $0.00. 31537350010013200160 R 2014 $..17.33 $295:12. 12f3012014 $303.OB $0.00 31537350010013200160 R 2013 1.7,96 $291.52 3/20/2014 .$299,49 MOB 31537350010013200160'. R: 2012. $34:32 $191.24 3112/20§3 $325.56. $0.00 eluA�aer . r D&T Ventures Ai dghts raserv0d, Cnpyeght t9S999d019 �y I of 1 9/25/2420, I. 3 P 'iVr"1tN�:J1'.3 LatitlM$* Web dlifldalRecords Search CODE EWORCEMENT SPECIAL. MAGISTRATE THE CITY OF OKEECHOBEE, FLORIDA CASE NO. 1 B-043 CITY OF OKEECHOBEE, PETITIONER, .vs. OW-LPAPM 'I`M8 CAUSE came before the Code Enforcement Hoard, City of Okeechobee, for public hearing on J ang 7 4 20 .. After due notice to the respondent, the Baud having heard evidence on the alleged violation by witnesses or affidavit makes the following findings: A. FINDINGS OF FACT-. Lots; 17 & E t ofLast I6 BW 132 Section: City ofOkeeohidrao Parcel: 3-15-37-35-0010-01320-01 Gil Property location; 914 NW 2"r Strect, Okeechobee, FL Property owner. Gloria Rodriguez Property has been found to have an unsafe house with roofdamage which needs, to be demolished„ H, CONCLUSIONS OF LAW. The ovmor ®f tlrm property described above bus been found In violation of interntAlonal Property Maintenance Code Ch 3 Sao 304. LI(e) Unsafe C. ORDER.: The City of Okeechob,o C Enforcement Special Magistrate has determined you violated the-Intomational Prop .I a.tranancc Code, Clx3400 tid.I.1t0! t asare condittrcn r d 9r� rt� v ttvafcla , a cones n your property located Al-9jA V St. tEnt-Muphob -E Efyou do not correct the vlealati4n bffifare 3u* a 25 �til�or notify the Coda Enforr cradat Ofticar of the corrcctic n, the Magistrate Impose$ at ftsle of 5 per day contta-aenckng that (late and cone truing daily until the violation is corrected or the city is notified by You and verifies the correction, whichever first occurs. purther, iryou do not cacreet the violation by said data, a copy vfthis order as a clal€nof lion, shall be recorded In the offico of the Clork of Circuit Court, Okeechobee Catttnty, Florida, and once recorded, becomes a lien on real and personal property pursmant to Florida Statute 162. You have a right Within thirty days, to appeal this finding and order by Writ of Certioraris to the Circuit Count, Okeechobee County, Florida. If you correct then violation prior to the above date, it is your obligation to i contact the Code Enforcement Officer to verify such compllanco. Boolt8281Page1260 CFN#201 OQ8106 Page 1 of 2 hltysJfpita€eeo rclte achobeaiandrasazit,enroll.andrnsrlcebLlvafsasrcis'iatidax7tliarna-.64ueBsa otSora=assrchCtilorlaNaateB+tttRok6rseea�'tSetect£� lofimot9 Landmark Web Mial Racorda Search AGREED AND OFLIDMIED thin Xt� day of J"I _, 2UJ9--. CITY OF OKEECHOBEE, Petitioner a Respondent CODE BNBORCEMENT City of Okeechobm Florida 3pac Mag€strata A:�, ode nforce ent Offic ATTEST- Recording Secretary STAR OF FLORIDA COUNTY OF OWBECROBVE PERSONALLY appeared before th undersigned auihodty. Huger Azcona _ , . and , well known to me and known by me to ba the Cade Enforcement Special Magistra , da Enforcement Officer and Recording Secretary, r"peatIvrv, of the CITY OF OKE E13 CODA MFORCM41INT. SWORN TO AND SUBSC9MED before meis d day of 20A. Putu m. baw-& NOTARYP LIC My Coormission expires; e Newf �eaearr ec Fiena� Plewo return to: City of Okeechobee Code Enforcement 55 SE Y r Avenue Okeechobee, PL 34974 (863) 357-1971 Bookg2fl/Psga1251 CFN#2019008106 Pager 2 of 2 Melissa Claw From; code enforcement <codeenforcement7208 gmalke > Senn: Friday, November 01, 20191118 PM To: Melissa Close i I 2 Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, Plaintiff, M GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, CASE NO.: NOTICE OF LIS PENDENS TO: DEFENDANT(S), TERESA CAPPETTA, MARY CONERLY, IDA CONERLY AND ROY CONERLY AND ALL OTHERS WHOM IT MAY CONCERN: YOU ARE NOTIFIED OF THE FOLLOWING: (a) The Plaintiff has instituted this action against you seeking ("to foreclose a mortgage" or "to partition" or "to quiet title" or other type of action) with respect to the property described below. (b) The Plaintiff(s) in this action is/are: City of Okeechobee Florida Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM (c) The date of the institution of this action is OR: the date on the Clerk's electronic receipt for the action's filing is OR: the case number of the action is as shown in the caption. (d) The property that is the subject of this action is in described as follows: County, Florida, and is Lot 17 and the East "% of Lot 16, Block 132, Town of Okeechobee, according to the plat thereof recorded in Plat Book 2, page 17, Public Records of Okeechobee County, Florida. Subject to all restrictions, limitations and covenants running with the title to the property. Subject property is the homestead of the Grantor. DATED ON this 2nd day of November, 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARMS & FUMERO, P.A. 750 Park of Commerce Blvd., Suite 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: rhvden('t)nasonvea ,er.com Attorneys for the Plaintiff Florida Bar No.: 50839 By: /s/ R, Sze- g�LoU ay� R. GREGORY HYDEN Doc No: 979815 Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): GLORIA RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algun tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Fl. 34986, (772) 807-4370, al menos 7 dias antes de su fecha de comparecencia o inmediatamente despues de haber recibido esta notificaci6n si faltan menos de 7 dias para su cita en el tribunal. Si tiene discapacidad auditiva o de habla, llame al 711. KREYOL: Si ou se you moun ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you Seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou paret nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou soud ouswa bebe, rele 711. DATED: CLERK OF THE COUNTY COURT M. Doc No: 979879 Deputy Clerk (SEAL) Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): RAUL RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algun tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Fl. 34986, (772) 807-4370, al menos 7 dias antes de su fecha de comparecencia o inmediatamente despues de haber recibido esta notificaci6n si faltan menos de 7 dias para su cita en el tribunal. Si tiene discapacidad auditiva o de habla, llame al 711. KREYOL: Si ou se you moun ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you Seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou paret nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou soud ouswa bebe, rele 711. DATED: CLERK OF THE COUNTY COURT M. Doc No: 979881 Deputy Clerk (SEAL) Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): NOE RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algun tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Fl. 34986, (772) 807-4370, al menos 7 dias antes de su fecha de comparecencia o inmediatamente despues de haber recibido esta notificaci6n si faltan menos de 7 dias para su cita en el tribunal. Si tiene discapacidad auditiva o de habla, llame al 711. KREYOL: Si ou se you moun ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you Seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou paret nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou soud ouswa bebe, rele 711. DATED: CLERK OF THE COUNTY COURT M. Doc No: 979881 Deputy Clerk (SEAL) Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, Plaintiff, CASE NO.: 4-lo-)�ccaDonoq V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): GLORIA RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "PlaintifUPlaintifrs Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algun tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Ft. 34986, (772) 807-4370, at menos 7 dias antes de su fecha de comparecencia o inmediatamente despues de haber recibido esta notificaci6n si fahan menos de 7 dias para su cita en el tribunal. Si tiene discapacidad auditiva o de habla, llame at 711. KREYOL: Si ou se you moun ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou paret nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou soud ouswa bebe, rele 711. DATED:,vOJOWW14rl «LC�Qo Z Doc No: 979879 Sharon Robertson, CIerK CLERK OF THE COUNTY COUR By. Deputy Clerk (SEAL) Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE No.: LAr-1&C)A 0 C-C D90 1 Qt 0/1 Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): RAUL RODRIGUEZ 17324 NW 213'H DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you. Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algnn tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Fl. 34986, (772) 807-4370, al menos 7 dias antes de su fecha de comparecencia o inmediatamente despu6s de haber recibido esta notificaci6n si faltan menos de 7 dias para su cita en el tribunal- Si tiene discapacidad auditiva o de habla, llame al 711. KREYOL: Si ou se you moue ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you Seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou par6t nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou soud ouswa b6be, rele 711. �/ � 1 * -MAW Sharon Robertson, Clerk MTHE COUNTY COURT Deputy Clerk (SEAL) Doc No: 979881 Filing # 115984127 E-Filed 11/02/2020 01:24:03 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, /� ,c� CASE NO.: ly�(c��C-wL-)0P Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ, Defendants, SUMMONS: PERSONAL SERVICE ON A NATURAL PERSON TO DEFENDANT(S): NOE RODRIGUEZ 17324 NW 213TH DRIVE HIGH SPRINGS, FL 32643-6403 IMPORTANT A lawsuit has been filed against you. You have 20 calendar days after this summons is served on you to file a written response to the attached complaint/petition with the clerk of this circuit court. A phone call will not protect you_ Your written response, including the case number given above and the names of the parties, must be filed if you want the court to hear your side of the case. If you do not file your written response on time, you may lose the case, and your wages, money, and property may thereafter be taken without further warning from the court. There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may call an attorney referral service or a legal aid office (listed in the phone book). If you choose to file a written response yourself, at the same time you file your written response to the court you must also mail or take a copy of your written response to the "Plaintiff/Plaintiff's Attorney" named below. R. Gregory Hyden, Esq. NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/02/2020 01:24:03 PM 750 Park of Commerce Blvd., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 686-3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the complaint/petition in this lawsuit on the above named defendant(s). If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algun tipo de adecuaci6n para poder participar de este procedimiento, usted tiene derecho a que se le ayude hasta cierto punto y sin costo alguno. Por favor comuniquese con Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, FL 34986, (772) 807-4370, al menos 7 dias antes de su fecha de comparecencia o inmediatamente despues de haber recibido esta notificaci6n si faltan menos de 7 dias para su cita en el tribunal. Si tiene discapacidad auditiva o de habla, llame al 711. KREYOL: Si ou se you moun ki andikape epi ou bezwen nenp6t akomodasyon you ou ka patisipe nan pwose sa-a, ou gen dwa, san ou pa gen you-ou peye anyen, you yo ba-ou you seri de asistans. Tanpri kontakte Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie FL 34986, (772) 807-4370 omwen 7 jou alavans jou ou gen you-ou par& nan tribunal -la, ouswa imedyatman kote ou resevwa notifikasyon-an si ke li mwens ke 7 jou; si ou loud ouswa bebe, rele 711. Sharon Robertson, Clerk CLERK OF THE COUNTY COURT Deputy Clerk (SEAL) Doc No: 9798 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANT GLORIA RODRIGUEZ COMES NOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff 'or "City"), by and through the undersigned counsel, pursuant to Fla. R. Civ. P. 1.370, and hereby serves this Request for Admissions upon the Defendant, GLORIA RODRIGUEZ, ("Rodriguez") to be responded to within the time period prescribed by the Florida Rules of Civil Procedure. Rodriguez is directed to admit or deny the truth of the matters set forth herein and is instructed that if a denial or admission pertains only to part of the matter to which the request is directed, Rodriguez shall specify so much of the matter which is true and qualify or deny the remainder of the matter. Rodriguez is also directed that she may not give lack of information as a reason for failure to admit or deny any matter requested herein unless Rodriguez certifies that she has made a reasonable inquiry and that the information known or readily obtainable by Conerly is insufficient to enable her to admit or deny the matter set forth therein. DEFINITIONS l . "Complaint" means the Complaint for foreclosure of the City's municipal lien filed Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non- identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. every." 8. The words "any" and "all" shall be considered to include "each" and "each and 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS If you object to fully identifying a document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (1) the nature of the privilege claimed (including work product); (2) if the privilege is being asserted in connection with a claim or defense governed by state law, the state privilege rule being invoked; (3) the date of the document, electronically stored information or oral communication; (4) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (5) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (6) the general subject matter of the document, electronically stored information or oral communication. PLEASE ADMIT THE FOLLOWING 1. Admit that the Property is in violation of Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 2. Admit that the Property's violations were referred to the Code Enforcement Board matter number 18-043. Response: 3. Admit that the Code Enforcement Board entered a. Lien/Order against the Property on July 3, 2019. Response: 4. Admit that the City sent a letter dated October 17, 2019 that the fines stemming from the Lien/Order had accrued for over 90 days. Response: 5. Admit that the Property is still not in compliance with Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 6. Admit that the fines stemming from the Lien/Order have not been paid. Response: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213"' Drive, High Springs, Florida 32643 on this 6f day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghyden(ii)nasonyea, er.com Attorneys for the City of Okeechobee By: /s/ R� 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981663 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANT RAUL RODRIGUEZ COMES NOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff 'or "City"), by and through the undersigned counsel, pursuant to Fla. R. Civ. P. 1.370, and hereby serves this Request for Admissions upon the Defendant, RAUL RODRIGUEZ, ("Rodriguez") to be responded to within the time period prescribed by the Florida Rules of Civil Procedure. Rodriguez is directed to admit or deny the truth of the matters set forth herein and is instructed that if a denial or admission pertains only to part of the matter to which the request is directed, Rodriguez shall specify so much of the matter which is true and qualify or deny the remainder of the matter. Rodriguez is also directed that he may not give lack of information as a reason for failure to admit or deny any matter requested herein unless Rodriguez certifies that he has made a reasonable inquiry and that the information known or readily obtainable by Rodriguez is insufficient to enable his to admit or deny the matter set forth therein. DEFINITIONS l . "Complaint" means the Complaint for foreclosure of the City's municipal lien filed Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non- identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. every." 8. The words "any" and "all" shall be considered to include "each" and "each and 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS If you object to fully identifying a document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (1) the nature of the privilege claimed (including work product); (2) if the privilege is being asserted in connection with a claim or defense governed by state law, the state privilege rule being invoked; (3) the date of the document, electronically stored information or oral communication; (4) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (5) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (6) the general subject matter of the document, electronically stored information or oral communication. PLEASE ADMIT THE FOLLOWING 1. Admit that the Property is in violation of Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 2. Admit that the Property's violations were referred to the Code Enforcement Board matter number 18-043. Response: 3. Admit that the Code Enforcement Board entered a. Lien/Order against the Property on July 3, 2019. Response: 4. Admit that the City sent a letter dated October 17, 2019 that the fines stemming from the Lien/Order had accrued for over 90 days. Response: 5. Admit that the Property is still not in compliance with Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 6. Admit that the fines stemming from the Lien/Order have not been paid. Response: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213"' Drive, High Springs, Florida 32643 on this 6f day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghyden(ii)nasonyea, er.com Attorneys for the City of Okeechobee By: /s/ R� 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981664 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S REQUEST FOR ADMISSIONS DIRECTED TO DEFENDANT NOE RODRIGUEZ COMES NOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff 'or "City"), by and through the undersigned counsel, pursuant to Fla. R. Civ. P. 1.370, and hereby serves this Request for Admissions upon the Defendant, NOE RODRIGUEZ, ("Rodriguez") to be responded to within the time period prescribed by the Florida Rules of Civil Procedure. Rodriguez is directed to admit or deny the truth of the matters set forth herein and is instructed that if a denial or admission pertains only to part of the matter to which the request is directed, Rodriguez shall specify so much of the matter which is true and qualify or deny the remainder of the matter. Rodriguez is also directed that he may not give lack of information as a reason for failure to admit or deny any matter requested herein unless Rodriguez certifies that he has made a reasonable inquiry and that the information known or readily obtainable by Rodriguez is insufficient to enable his to admit or deny the matter set forth therein. DEFINITIONS l . "Complaint" means the Complaint for foreclosure of the City's municipal lien filed Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non- identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. every." 8. The words "any" and "all" shall be considered to include "each" and "each and 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS If you object to fully identifying a document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (1) the nature of the privilege claimed (including work product); (2) if the privilege is being asserted in connection with a claim or defense governed by state law, the state privilege rule being invoked; (3) the date of the document, electronically stored information or oral communication; (4) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (5) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (6) the general subject matter of the document, electronically stored information or oral communication. PLEASE ADMIT THE FOLLOWING 1. Admit that the Property is in violation of Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 2. Admit that the Property's violations were referred to the Code Enforcement Board matter number 18-043. Response: 3. Admit that the Code Enforcement Board entered a. Lien/Order against the Property on July 3, 2019. Response: 4. Admit that the City sent a letter dated October 17, 2019 that the fines stemming from the Lien/Order had accrued for over 90 days. Response: 5. Admit that the Property is still not in compliance with Sections 304.1.1(8) and Section 304.7 of the City's Code of Ordinances. Response: 6. Admit that the fines stemming from the Lien/Order have not been paid. Response: CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213"' Drive, High Springs, Florida 32643 on this 6f day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghyden(ii)nasonyea, er.com Attorneys for the City of Okeechobee By: /s/ R� 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981666 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION DIRECTED TO DEFENDANT, GLORIA RODRIGUEZ COMESNOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff' or "City"), by and through the undersigned counsel, and files this First Request for Production to be responded to by the Defendant, GLORIA RODRIGUEZ ("Defendant" or "Conerly"), within forty-five (45) days of receipt of this notice for purposes of inspection and copying pursuant to Fla. R. Civ. P. 1.350. The documents and tangible things are to be produced at the offices of Nason, Yeager, Gerson, Harris & Fumero, P.A., 750 Park of Commerce Boulevard, Suite 210, Boca Raton, Florida 33487. These requests are, in accordance with Fla. R. Civ. P. 1.350, continuing in nature and the Defendant is required to provide such additional information, documents or tangible things as the Defendant, attorneys for the Defendant, or anyone acting on behalf of or in concert with the Defendant, may have or may obtain between the time the responses are served and the time of trial. In answering these requests, the Defendant is requested to furnish all information which is available to her or to any attorneys representing her, including, but not limited to, information in the possession of any attorneys, agents, investigators, representatives, or anyone acting in cooperation or in concert with her. DEFINITIONS Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM 1. "Complaint" means the Complaint for foreclosure of the City's municipal lien filed on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non -identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. 8. The words "any" and "all" shall be considered to include "each" and "each and every." 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS With respect to each of the requests set forth herein, you shall identify and/or produce all documents and tangible things which are known to you or which can be located or discovered by you through diligent effort on the part of you, your employees, representatives, attorneys, or accountants, including but not limited to all documents and tangible things which are in the possession of you or your representatives, attorneys, or accountants, or accessible to you or your representatives, attorneys, or accountants. You shall categorize each response so as to conform to the numbered request. Destroyed Documents or Tangible Things If any documents requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of a true and correct copy thereof a list of such documents so lost or destroyed together with the following information: (a) the date of the origin; (b) a brief description of such document; (c) the author of the document; (d) the date upon which the document was lost or destroyed; and (e) a brief statement of the manner in which the document was lost or destroyed. Similarly, if any tangible things requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of the tangible things a list of such tangible things so lost or destroyed together with the following information: (a) the make and model of the tangible thing; (b) a brief description of the information contained within the tangible thing; (c) the date upon which the tangible thing was lost or destroyed; (d) a brief statement of the manner in which the tangible thing was lost or destroyed; and (e) if applicable, any phone numbers associated with the tangible thing. Obiections to Production In the event that any objection is made to the production of any document fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such document a list of each document withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the document from production; and (c) a brief description of the documents withheld, including (i) the date upon which the document was originated, (ii) the identity of its author or preparer, (iii) the identity of each person who was a recipient of the document, (iv) the specific request which encompasses the document, (v) a brief description of the subject matter of the document, and (vi) the identity of all persons who have personal knowledge of the subject matter. In the event that any objection is made to the production of any tangible thing fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such tangible thing a list of each tangible thing withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the tangible things from production; and (c) a brief description of the tangible things withheld, including (i) the make and model of each tangible thing, (ii) a brief description of the relevant subject matter contained within the tangible thing, (iii) the identity of all persons who have personal knowledge of the subject matter contained within the tangible thing; and (iv) if applicable, any phone numbers associated with the tangible thing. If you object to a particular request, or portion thereof, you must produce all documents called for which are not subject to that objection. Similarly, whenever a document is not produced in full for some other reason, you must state with particularity the reason(s) it is not being produced in full, and describe, to the best of your knowledge, information, and belief, and with as much particularity as possible, those portions of the document which are not produced. If you object to fully identifying a tangible thing, document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (a) the nature of the privilege claimed (including work product); (b) if the privilege is being asserted in connection with a claim or defense governed by state law, state privilege rule being invoked; (c) the date of the document, electronically stored information or oral communication; (d) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (e) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (f) the general subject matter of the document, electronically stored information or oral communication. REQUEST FOR PRODUCTION OF DOCUMENTS AND TANGIBLE THINGS All Documents evidencing your legal ownership interest in the Property; and, 2. All Documents evidencing your attempts to bring the Property into compliance with Sections 304.1.1(8) and 304.7 of the City's Code of Ordinances; and, 3. All Documents evidencing your payment of the $25.00 daily fines stemming from the Lien/Order entered July 3, 2019; and, 4. All Documents evidencing your communications with the City after receipt of the City's October 17, 2019 letter. 5. All Documents evidencing your communications with the City after the City posted notices on the Property related to the Lien/Order; and, 6. All Documents in support of any defense Conerly raises in this case. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213th Drive, High Springs, Florida 32643 on this 6th day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: hydeni&nasonyeaer.corn Attorneys for the City of Okeechobee By: /s/ R IT:am _q R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981723 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION DIRECTED TO DEFENDANT, RAUL RODRIGUEZ COMESNOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff' or "City"), by and through the undersigned counsel, and files this First Request for Production to be responded to by the Defendant, RAUL RODRIGUEZ ("Defendant" or "Conerly"), within forty-five (45) days of receipt of this notice for purposes of inspection and copying pursuant to Fla. R. Civ. P. 1.350. The documents and tangible things are to be produced at the offices of Nason, Yeager, Gerson, Harris & Fumero, P.A., 750 Park of Commerce Boulevard, Suite 210, Boca Raton, Florida 33487. These requests are, in accordance with Fla. R. Civ. P. 1.350, continuing in nature and the Defendant is required to provide such additional information, documents or tangible things as the Defendant, attorneys for the Defendant, or anyone acting on behalf of or in concert with the Defendant, may have or may obtain between the time the responses are served and the time of trial. In answering these requests, the Defendant is requested to furnish all information which is available to her or to any attorneys representing her, including, but not limited to, information in the possession of any attorneys, agents, investigators, representatives, or anyone acting in cooperation or in concert with her. DEFINITIONS Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM 1. "Complaint" means the Complaint for foreclosure of the City's municipal lien filed on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non -identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. 8. The words "any" and "all" shall be considered to include "each" and "each and every." 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS With respect to each of the requests set forth herein, you shall identify and/or produce all documents and tangible things which are known to you or which can be located or discovered by you through diligent effort on the part of you, your employees, representatives, attorneys, or accountants, including but not limited to all documents and tangible things which are in the possession of you or your representatives, attorneys, or accountants, or accessible to you or your representatives, attorneys, or accountants. You shall categorize each response so as to conform to the numbered request. Destroyed Documents or Tangible Things If any documents requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of a true and correct copy thereof a list of such documents so lost or destroyed together with the following information: (a) the date of the origin; (b) a brief description of such document; (c) the author of the document; (d) the date upon which the document was lost or destroyed; and (e) a brief statement of the manner in which the document was lost or destroyed. Similarly, if any tangible things requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of the tangible things a list of such tangible things so lost or destroyed together with the following information: (a) the make and model of the tangible thing; (b) a brief description of the information contained within the tangible thing; (c) the date upon which the tangible thing was lost or destroyed; (d) a brief statement of the manner in which the tangible thing was lost or destroyed; and (e) if applicable, any phone numbers associated with the tangible thing. Obiections to Production In the event that any objection is made to the production of any document fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such document a list of each document withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the document from production; and (c) a brief description of the documents withheld, including (i) the date upon which the document was originated, (ii) the identity of its author or preparer, (iii) the identity of each person who was a recipient of the document, (iv) the specific request which encompasses the document, (v) a brief description of the subject matter of the document, and (vi) the identity of all persons who have personal knowledge of the subject matter. In the event that any objection is made to the production of any tangible thing fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such tangible thing a list of each tangible thing withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the tangible things from production; and (c) a brief description of the tangible things withheld, including (i) the make and model of each tangible thing, (ii) a brief description of the relevant subject matter contained within the tangible thing, (iii) the identity of all persons who have personal knowledge of the subject matter contained within the tangible thing; and (iv) if applicable, any phone numbers associated with the tangible thing. If you object to a particular request, or portion thereof, you must produce all documents called for which are not subject to that objection. Similarly, whenever a document is not produced in full for some other reason, you must state with particularity the reason(s) it is not being produced in full, and describe, to the best of your knowledge, information, and belief, and with as much particularity as possible, those portions of the document which are not produced. If you object to fully identifying a tangible thing, document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (a) the nature of the privilege claimed (including work product); (b) if the privilege is being asserted in connection with a claim or defense governed by state law, state privilege rule being invoked; (c) the date of the document, electronically stored information or oral communication; (d) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (e) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (f) the general subject matter of the document, electronically stored information or oral communication. REQUEST FOR PRODUCTION OF DOCUMENTS AND TANGIBLE THINGS All Documents evidencing your legal ownership interest in the Property; and, 2. All Documents evidencing your attempts to bring the Property into compliance with Sections 304.1.1(8) and 304.7 of the City's Code of Ordinances; and, All Documents evidencing your payment of the $25.00 daily fines stemming from the Lien/Order entered July 3, 2019; and, 4. All Documents evidencing your communications with the City after receipt of the City's October 17, 2019 letter. All Documents evidencing your communications with the City after the City posted notices on the Property related to the Lien/Order; and, All Documents in support of any defense Conerly raises in this case. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213th Drive, High Springs, Florida 32643 on this 6th day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: hydeni&nasonyeaer.corn Attorneys for the City of Okeechobee By: /s/ R IT:am _q R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981726 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, V. GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PLAINTIFF'S FIRST REQUEST FOR PRODUCTION DIRECTED TO DEFENDANT, NOE RODRIGUEZ COMESNOW, the Plaintiff, CITY OF OKEECHOBEE, FLORIDA ("Plaintiff' or "City"), by and through the undersigned counsel, and files this First Request for Production to be responded to by the Defendant, NOE RODRIGUEZ ("Defendant" or "Conerly"), within forty-five (45) days of receipt of this notice for purposes of inspection and copying pursuant to Fla. R. Civ. P. 1.350. The documents and tangible things are to be produced at the offices of Nason, Yeager, Gerson, Harris & Fumero, P.A., 750 Park of Commerce Boulevard, Suite 210, Boca Raton, Florida 33487. These requests are, in accordance with Fla. R. Civ. P. 1.350, continuing in nature and the Defendant is required to provide such additional information, documents or tangible things as the Defendant, attorneys for the Defendant, or anyone acting on behalf of or in concert with the Defendant, may have or may obtain between the time the responses are served and the time of trial. In answering these requests, the Defendant is requested to furnish all information which is available to her or to any attorneys representing her, including, but not limited to, information in the possession of any attorneys, agents, investigators, representatives, or anyone acting in cooperation or in concert with her. DEFINITIONS Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM 1. "Complaint" means the Complaint for foreclosure of the City's municipal lien filed on November 2, 2020. 2. "Property" means the real property located at 914 N.W. 2nd Street, Okeechobee, Florida 32643-6403. 3. "Document" or "Documents" refer to any printed, written, taped, recorded, graphic, electronically stored information (including, but not limited to emails and text messages), or other tangible matter, from whatever source, however produced or reproduced, or stored, whether electronically or hard copy, whether in draft or otherwise, whether sent or received, or neither, including, but not limited to, the original, a copy (if the original is not available), and all non -identical copies (whether different from the original because of notes made on or attached to such copy or otherwise) or any and all writings, correspondence, letters, cables, telexes, contracts, proposals, agreements, minutes, acknowledgments, notes, memoranda, analyses, projections, work papers, books, appointment books, manuals, circulars, catalogs, studies, evaluations, journals, statistical records, drawings, sketches, forecasts or appraisals, papers, records, reports, diaries, statements, questionnaires, schedules, computer programs or data, data storage systems, electronic mail, instant messages, books of account, calendars, graphs, charts, transcripts, tapes, or recordings, photographs, pictures or film, ledgers, registers, work sheets, summaries, digests, financial statements, and all other information where data, records or compilations, including all underlying, supporting or preparatory material are now in your possession, custody or control, or available to you, your counsel, accountants, agents, representatives or associates. With regard to electronically stored information, documents must be produced in native format with all relevant metadata accessible as it is kept in the normal course of business. 4. "Communication" means each and every disclosure, transfer or exchange of information, whether oral or in writing, and whether in person, by telephone, by mail or otherwise, including, but not limited to, discussions, statements, negotiations, inquiries, requests, notices, responses, demands or complaints. When used in conjunction with a corporation, communication means all communications to which the corporation, its agents, employees, officers or directors were parties. 5. "Relating to" means constituting or evidencing and directly or indirectly mentioning, describing, referring to, pertaining to, being connected with or reflecting upon the stated subject matter. 6. "Person" includes natural persons, corporations, firms, companies, partnerships, associations, governmental or state agencies, departments and any other public, private or legal entity. 7. The words "and" and "or" shall be construed conjunctively or disjunctively as necessary to make a request inclusive rather than exclusive. 8. The words "any" and "all" shall be considered to include "each" and "each and every." 9. The singular of any word shall include the plural, and the plural of any word shall include the singular. 10. "Identify" and "identification" when used in reference to a document or documents means to state the date, the author (if different, the signor or signors), the address, type of document (e.g., letter, memorandum, telegram, chart, sketch, or diagram) and any other means of identifying with sufficient particularity to meet the requirements for its inclusion in a request for production of documents pursuant to the Florida Rules of Civil Procedure and Florida Family Law Rules. If any such document was, but no longer is, in possession or subject to control, state what disposition was made of it and the reason for that disposition. 11. If you do not clearly understand, or have any questions about, the definitions, instructions, or any request for documents, please contact the undersigned counsel, promptly for clarification. 12. For each business entity, an attempt has been made to include in its name, where applicable, a notation of its corporate form. For the purposes of this production, consider the name of a business entity as including the notation of corporate form, if applicable. As an example, "XYZ" is to be considered the same as "XYZ, Inc." or "XYZ Corporation." If any document is withheld on a claim of privilege, you are instructed to identify the document by author, date, subject matter and recipients. INSTRUCTIONS With respect to each of the requests set forth herein, you shall identify and/or produce all documents and tangible things which are known to you or which can be located or discovered by you through diligent effort on the part of you, your employees, representatives, attorneys, or accountants, including but not limited to all documents and tangible things which are in the possession of you or your representatives, attorneys, or accountants, or accessible to you or your representatives, attorneys, or accountants. You shall categorize each response so as to conform to the numbered request. Destroyed Documents or Tangible Things If any documents requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of a true and correct copy thereof a list of such documents so lost or destroyed together with the following information: (a) the date of the origin; (b) a brief description of such document; (c) the author of the document; (d) the date upon which the document was lost or destroyed; and (e) a brief statement of the manner in which the document was lost or destroyed. Similarly, if any tangible things requested herein or fairly comprised within the scope of the following requests have been lost or destroyed, you shall provide in lieu of the tangible things a list of such tangible things so lost or destroyed together with the following information: (a) the make and model of the tangible thing; (b) a brief description of the information contained within the tangible thing; (c) the date upon which the tangible thing was lost or destroyed; (d) a brief statement of the manner in which the tangible thing was lost or destroyed; and (e) if applicable, any phone numbers associated with the tangible thing. Obiections to Production In the event that any objection is made to the production of any document fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such document a list of each document withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the document from production; and (c) a brief description of the documents withheld, including (i) the date upon which the document was originated, (ii) the identity of its author or preparer, (iii) the identity of each person who was a recipient of the document, (iv) the specific request which encompasses the document, (v) a brief description of the subject matter of the document, and (vi) the identity of all persons who have personal knowledge of the subject matter. In the event that any objection is made to the production of any tangible thing fairly comprised within the scope of the following requests, you shall furnish in lieu of production of such tangible thing a list of each tangible thing withheld from production together with the following information: (a) the reason for withholding production; (b) a statement of facts constituting the basis for your withholding the tangible things from production; and (c) a brief description of the tangible things withheld, including (i) the make and model of each tangible thing, (ii) a brief description of the relevant subject matter contained within the tangible thing, (iii) the identity of all persons who have personal knowledge of the subject matter contained within the tangible thing; and (iv) if applicable, any phone numbers associated with the tangible thing. If you object to a particular request, or portion thereof, you must produce all documents called for which are not subject to that objection. Similarly, whenever a document is not produced in full for some other reason, you must state with particularity the reason(s) it is not being produced in full, and describe, to the best of your knowledge, information, and belief, and with as much particularity as possible, those portions of the document which are not produced. If you object to fully identifying a tangible thing, document, electronically stored information or oral communication because of a privilege, you must nevertheless provide the following information, unless divulging the information would disclose the privileged information: (a) the nature of the privilege claimed (including work product); (b) if the privilege is being asserted in connection with a claim or defense governed by state law, state privilege rule being invoked; (c) the date of the document, electronically stored information or oral communication; (d) if a document: its type (e.g., letter or memorandum) and, if electronically stored information, the software application used to create it (e.g., MS Word or MS Excel Spreadsheet), and the custodian, location and such other information sufficient to identify the material for a subpoena duces tecum, or a production request, including where appropriate the author, the addressee and, if not apparent, the relationship between the author and addressee; (e) if an oral communication: the place where it was made, the names of the persons present while it was made and, if not apparent, the relationship of the persons present to the declarant; and (f) the general subject matter of the document, electronically stored information or oral communication. REQUEST FOR PRODUCTION OF DOCUMENTS AND TANGIBLE THINGS All Documents evidencing your legal ownership interest in the Property; and, 2. All Documents evidencing your attempts to bring the Property into compliance with Sections 304.1.1(8) and 304.7 of the City's Code of Ordinances; and, All Documents evidencing your payment of the $25.00 daily fines stemming from the Lien/Order entered July 3, 2019; and, 4. All Documents evidencing your communications with the City after receipt of the City's October 17, 2019 letter. All Documents evidencing your communications with the City after the City posted notices on the Property related to the Lien/Order; and, All Documents in support of any defense Conerly raises in this case. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213th Drive, High Springs, Florida 32643 on this 6th day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: hydeni&nasonyeaer.corn Attorneys for the City of Okeechobee By: /s/ R IT:am _q R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Doc No: 981728 Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, u GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S NOTICE OF SERVICE OF FIRST SET OF INTERROGATORIES COMES NOW, Plaintiff, CITY OF OKEECHOBEE, FLORIDA, pursuant to Florida Rule of Civil Procedure 1.340, by and through undersigned counsel, and hereby files and serves its First of Set of Interrogatories on the Defendant, Gloria Rodriguez, to be answered under oath, and in writing, within forty-five (45) days after service hereof CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213'h Drive, High Springs, Florida 32643 on this 6th day of November 2020. Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghydenOnason ea er.com Attorneys for the City of Okeechobee By: /s/ R, 0ii-e4T4n 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY Doc No: 981679 FBN: 558672 Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, u GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S NOTICE OF SERVICE OF FIRST SET OF INTERROGATORIES COMES NOW, Plaintiff, CITY OF OKEECHOBEE, FLORIDA, pursuant to Florida Rule of Civil Procedure 1.340, by and through undersigned counsel, and hereby files and serves its First of Set of Interrogatories on the Defendant, Raul Rodriguez, to be answered under oath, and in writing, within forty-five (45) days after service hereof CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213'h Drive, High Springs, Florida 32643 on this 6th day of November 2020. Doc No: 981680 Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghydenOnason ea er.com Attorneys for the City of Okeechobee By: /s/ R, 0ii-e4T4n 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM Filing # 116306411 E-Filed 11/06/2020 04:07:09 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTTY, FLORIDA CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CASE NO.: 47 2020 CC 000190 CC AXMX Plaintiff, u GLORIA RODRIGUEZ, RAUL RODRIGUEZ, and NOE RODRIGUEZ Defendants. PETITIONER'S NOTICE OF SERVICE OF FIRST SET OF INTERROGATORIES COMES NOW, Plaintiff, CITY OF OKEECHOBEE, FLORIDA, pursuant to Florida Rule of Civil Procedure 1.340, by and through undersigned counsel, and hereby files and serves its First of Set of Interrogatories on the Defendant, Noe Rodriguez, to be answered under oath, and in writing, within forty-five (45) days after service hereof CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and accurate copy of the foregoing document will be served by a process server to: Gloria Rodriguez, Paul Rodriguez and Noe Rodriguez, 17324 N.W. 213'h Drive, High Springs, Florida 32643 on this 6th day of November 2020. Doc No: 981694 Respectfully submitted, NASON, YEAGER, GERSON, HARRIS & FUMERO, P.A. 750 Park of Commerce Ave., Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 982-7114 Facsimile: (561) 982-7116 E-mail: ghydenOnason ea er.com Attorneys for the City of Okeechobee By: /s/ R, 0ii-e4T4n 2 R. GREGORY HYDEN FBN: 50839 JOHN FUMERO FBN: 716596 CARLYN KOWALSKY FBN: 558672 Electronically Filed Okeechobee Case # 202000019OCCAXMX 11/06/2020 04:07:09 PM Filing # 116722180 E-Filed 11/16/2020 02:16:53 PM ALACHUA COUNTY SHERIFFS OFFICE ALACHUA COUNTY, FLORIDA NON -ENFORCEABLE RETURN OF SERVICE Document Number* AS020CIV010392NON Agency Number - Court: OUT OF COUNTY County: OKEECHOBEE Case Number: 47202OCCO00190A AttorneylAgent: NASON, YEAGER, GERSON, HARRIS & FUMERO 750 PARK OF COMMERCE BLV 210 BOCA RATON, FL 33487 Plaintiff: CITY OF OKEECHOBEE, FLCIRIDP, Defendant: GLORIA RODRIGYEZ, RAUL RODRIGUEZ AND NOE RODRIGUEZ Type of Process: SUMMONS, COMPLAINT, EXHIBIT A-D, NOTICE OF LIS PENDENS INDIVIDUAI - PERSONAL SERVICE co PERSON TO BE SERVED; RODRIGUEZ, NOE 17324 NW 213TH DR, HIGH SPRINGS, FL C) C) Received the above narned writ on 111412020 at 12:10 PM, and served the same on 11/6/2020 at 8:33 AM, in Alachua County, Florida, by delivering a true copy of this writ together with a copy of the initial pleading, if any, with the date an(O hour of service endorsed thereon by me, to: RODRIGUEZ, NOE after the provisions as set forth in Section 48.031(1)(4 Florida Statutes have been met, x 75 x C) 0') SADIE DARNELL C) C) ALACHUA C) C) Cq C) Byi M. PRIVETTE, 496 Cn Service Fee: $120.00 Receipt No: 65525-20-D 0 0 -0 LD LL W Printed By: PCBALDWI ding # 115984127 E-Filed 11/02/2020 0114:03 PM IN THE COITNTY COUWr OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNW, FLORIDA CITY OF OKEECHOB EE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, CA$ E N O00 Plaintiff, A. lawsuit has been filed against you. You have 20 A adar days after this s uninions is k-rvred on you to file a written response to the attached complaint/petition with the clerk of this circuit court- A phone call will not protect you- Your written response, includmig the case number giveriabove and the names of the parties, must be riled if you want the court to hear your side of the case. If you do not site your written response on finie, you may lose the case, and your wages, money, and property n-my therealler be Uaken, without ftirther warning from the- courl.'rhere are o0wr legal req4ironients. You inay want to call an attorney right away. If you do not know an attormy,you may call an allomey rerewal service or a legal aid offlice (listed in the phone book), Ifyou eboose to file a written tespotm youtselt. at thew—ne titne you file your written response to the court you must ako mad or take a copy ofyour Written rcsPonw to the "PlaWiMplaintiMs Attmrwy" R. Gr*ry Hyden, IF4q, NA"? YEAGM GERSON, HARM & "AWM !P�A* 750 Park of Commerce Blvd-, Ste. 210 Boca Raton, Florida 33487 Telephone: (561) 6$&3307 THE STATE OF FLORIDA TO EACH SHERIFF OF THE STATE: You are commanded to serve this summons and a copy of the cornplaint/p6tiarn in this lawsuit on the above natned defendant(s), if you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cast to you, to the prevision of certain assistance. Please contact Lisa DiLucente-Jaramillo, 250 NW Country Club Drive, Suite 217, fort St Lucie, FL 34986, (772) 807-4370 at feast 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time- before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. SPANISH: Si usted es una persona discapacitada que necesita algArr tipo de adecuaci6n para poder participar de este procedimicrrto, usted tiene derecho a que se le ayude hasty cierto punto y sin costo a1guno. Por favor cornuniquese con Lisa DiLu nte-Jaramillo, 250 NW Country Club Drive, Suite 217, Port St. Lucie, Ft. 34986, (772) $07-4370, al rnenos. 7 d as antes de su fectia de comparecencia o inmediatar ente despues de haber recibido esta notificacnon si faltan metros de 7 dias para su cita en el trribunaL Si tiene discapacidad audit iva o de habla, llama at 711. K RF,YAL. Si ou se you mourn ki andikape epi ou bezwen nenpbt akomodasyon you ou ka patisipe nan pwos6 sa-a, ou gen dwa, san ou pa gen you-ou. peye anyen, you yo ba-ou you Seri de asistans. Tanpr kontakte Lisa DILucente-Jararnillo, 250 NW Country Club Drive, Suite 217, Port St, Lucia FL 34986, (772) 807-4370 omwen, 7 jou alavans jou ou gen poo—ou paret nan tribunal -la, ouswa imedyatman kote ou re;sevwa noiifikasyon-an si ke li mavens ke 7 jou si ou. sours ouswa Wb: , role 711, DATED: Wq 94�9t ] Sharon Robertson, Clerk CLERK OF THE COUNTY COURT Deputy Clerk (SEAL) Doe No- 9798 Filing # 117373989 E-Filed 11/30/2020 03:04:04 PM IN THE COUNTY COURT OF THE NINETEENTH JUDICIAL CIRCUIT IN AND FOR OKEECHOBEE COUNTY, FLORIDA CASE NO.: 47202OCCO0019OCCAXMX CITY OF OKEECHOBEE, FLORIDA, a municipal corporation organized under the laws of the State of Florida, Plaintiff; V, GLORIA RODRIGUIEZ, RAM.. RODRIGUEZ, and NOE RODRIGUEZ, Defendants,,. ACCEPTANCE OF SERVICE The undersigned attorney for Defendants, Gloria Rodriguez and Raul Rodriguez accepts service of the Summons and Complaint for the Defendants on November 30, 2020, COLIN M. CAM ERON, ESQ, Colin M. Cameron, Esq., P.A. 200 NE 4'h Ave, Okeechobee, FL 34972-2981 Telephone: (863) 763-8600 Email: cofifilli� Fla. Bar No: 270441 Doc No: 988808 Electronically Filed Okeechobee Case # 2020000190CCAXMX 11/30/2020 03:04:04 PM