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Item M8
BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: August 20, 2014 Department: County Attorney Bulk Item: Yes _ No x Staff Contact: Lisa Gran er 292-3470 AGENDA ITEM WORDING: Presentation of an offer by Dr. and Mrs. Harley Stock, prospective buyer of property located at 108 Old Fashion Road, Key largo, Florida to partially release the code compliance lien imposed against that property in code case CE12070048, Monroe County v. Juan Castaneda, in exchange for a payment of$30,000.00, ITEM BACKGROUND: On September 27, 2012 the Code Compliance Special Magistrate found Juan Castaneda and his property located at 108 Old Fashion Road, Tavernier, Florida in violation of County's vacation rental ordinance. Fines were imposed and have been accruing in the amount of$ 2,000 per day. Due to the irreparable and irreversible nature of the violation, a one time fine in the amount of$15,000 was also imposed. As of July 24, 2104, the total value of the County's lien is $1,334,085.70. This amount is composed of daily fines of$1,3 16,000.00, plus costs of$3,085.70�, plus the one time fine in the amount of$15,000. The code case remains open for non-compliance and failure to pay the outstanding fines, onetime fine and costs. The subject property is not homesteaded. The buyers wish to purchase the property through a short sale from the property owner and Wells Fargo Bank. However the property owner and property is encumbered with a number of outstanding liens including the County's lien. Wells Fargo Bank received a Final Judgment of Foreclosure against the property owner on this property on April 16, 2014. A foreclosure sale was scheduled for May 15, 2014 but has been continued to allow the potential purchasers the time to negotiate a short sale with Wells Fargo, a settlement with the County on its code lien, a settlement with the tax collector on its lien for delinquent tourist taxes and a settlement with the US government on its lien. While the County has not been named in the foreclosure action filed by Wells Fargo Bank, the County's lien is inferior to the bank's lien. The County has filed its own foreclosure and injunction action against the property owner,Juan Castaneda which would be rendered moot if the proposed offer is accepted by the Board of County Commissioners. Although Mr. Castaneda has been difficult to serve,he has communicated his consent to the proposed sale and partial release of lien through third parties. Even with the partial release of lien to allow this transaction, the County's lien would remain in place against Mr. Castaneda. The potential buyer is requesting that the County accept$30,000 as payment of the fines in exchange for a partial release of the County's lien. If the offer is accepted, the remaining amount of the outstanding lien would remain against Juan Castaneda. Staff recommends accepting the proposed amount of$30,000 provided the total amount is escrowed at closing and paid in full within 10 days from the date of the closing and the buyers provide an affidavit that the property will remain in compliance under their ownership. The affidavit is included in the backup. The proposed settlement offer falls outside of the authority granted to staff by Resolution 148- 2008, which does not contemplate the circumstances presented in this case. PREVIOUS RELEVANT BOCC ACTION:N/A CONTRACT/AGREEMENT CHANGES:N/A STAFF RECOMMENDATIONS: Accept settlement offer of$30,000 for payment of fines in exchange for a partial release of lien provided the total amount is escrowed at closing and paid in full within 10 days from the date of the closing. TOTAL COST: INDIRECT COST: BUDGETED: Yes No DIFFERENTIAL OF LOCAL REFERENCE: COST TO COUNTY: SOURCE OF FUNDS: REVENUE PRODUCING: Yes AMOUNT PER MONTH Year APPROVED BY: County Atty OMB/Purchasing Risk Management DOCUMENTATION: Included X Not Required DISPOSITION: AGENDA ITEM# AFFIDAVIT STATE OF FLORIDA COUNTY OF BROWARD 1. The undersigned have entered into a contract with Juan Carlos Castaneda to purchase the residence owned by Mr. Castaneda at 108 Old Fashion Road, Tavernier, Florida. 2. We are aware that a Code Enforcement case was filed against Mr. Castaneda for advertising and using the residence for short-term rentals in violation of Monroe County Ordinances. 3. We are notpurchasing the property to use it for short-term rentals and we will not advertise or use the property for short-term rentals because we know that to do so would be in violation of Monroe County ordinances. 4. We are aware that the Monroe County Board of County Commissioners is relying on the truthfulness of the assurances we are giving herein in order to justify the release of the Code Enforcement liens placed by Monroe County so that we can purchase the property. FURTHER AFFLANTS SAYE711 NAUGHT. By. HA LEY CK B ., E. OBIN E. Awz—,- TO& Mailing Address: 744 NW 101"' Ten STATE OF FLORIDA Plantation, FL 33324 COUNTY OF BROWARD r Sworn to and subscribed before me on this day of August, 2014 by Harley V. Stock, and Robin E. Stock, who are personally known to me or who have produced _ ,(•� { ',k , (�� .Vt ,s as identification. My Commission Expires: Notary Pub] te of Florida + !'n';•.. SUSAN V, CME1JES25 ,moo"" -- ''•• [ G3 affix stamp/sea]in space provided) !Votary Public•State of Florida •5 My Comte.Expires Mar 22,2015 Commission #EE 76603 ..... +• Sanded Through Ualional IJnlary Assn go cn .00 n $ > :6 o O a V `� N o o d obi aoa 7 V ° M O Yi uo .sop w 5 cdd V o a t° ° ° v m A W z, '� V N Gl C07 U U �5 h cr yy° O gy�pr+ O 00 h d N •" � 3�i b C/ !r d O Lur u ° F, ro v Ei a eo o o C° \ o e 00 5 a v m °�' o $ � � � p O �n q o Q a�i ai 78 a ro eC pp p w a c No chi o 4i w ev °' 3 v 1 46 -8 w ro " > s� `� " -S ca CO ro ° ° k] ~ � N v M K1 .D N ° u O V a o a . § ■ � © o _ / / R I k bo � � 2 � u ■ A \ / cu ~o § � 7 ƒ 5 >i ) 2 I § k2 § � 7 0 & B % $ / 4 " cc ; � � w 33 � k 7 ° (A S \ \ ! � /I BEFORE THE COUNTY CODE COMPLIANCE SPECIAL MAGISTRATE MONROE COUNTY,FLORIDA MONROE COUNTY FLORIDA, ) Petitioner, t Case No.CE 1,40704el ff Vs. 1 Subject Props Real Estade Number. ) Doc9 1903689 10/18/2012 10:25M Filed A Recorded in Official Records of Respondent(s). ) MONROE COUNTY DANNY L. KOLHASE r FINAL ORDER Having fully considered the evidence presented at hearing,Including testimony of the Cade Compliance Inspector(s)and/or witnesses under oath,the following Findings of Fad and Conclusions of Law are ORDERED: ,�/�[Madng The Responderd(s)and/or Authorized Representative /1� �,hlh L1lf'.0• ESQ- �rellVeto not present an di not contest the violations)set forth In the Notice of VlolatkiNNaSwnco!porated herein as if fu set forth. �.%Pdti7 e sfane� (�i�i2ess o^lly� (4 The Respondent(,)Ware the owner(s)of property located within Monroe County and washvem duly noticed of the hearing. (vi The Respondents)Ware in violation of the Monroe County Code(s)as fully set forth in the Notice of Violation/Notice of Hearing served upon the Respondent(,. (y)'The violation(s)Is found to be irreparable or irreversible and a one-time fine of$ '/' 464-010 is ORDERED,payable within days of this Order. (►/y Pursuant to Section 182.07(2)of Florida Statutes all costs incurred by the County In prosecuting the case is ordered to be paid within thirty(30)days of compliance. Costs will continue to accrue until compliance is achieved and the case is closed. (-4The Respondent(s)shall comply with the Cods(s)relined to In the Notice of Violation/Notkre of Hearing on or before 4-l d��dl�a (°THE COMPLIANCE DATE"). (j41n the event the violation(s)were or are not corrected on THE COMPLIANCE DATE PREVIOUSLY ORDERED or on THE COMPLIANCE DATE SET FORTH HEREIN,ffne(s)in the dollar amount of: S ��^— c>- v `� -0 / 0400, L?o for each day beginning on THE DAY AFTER THE COMPLIANCE DATE that the Respondent(s)Ware in violation Ware hereby ORDERED. ( ) It is further ordered,that the County is hereby authorized to mike all reasonable repairs including demolition which am required to bring the property into compliance and charge the Respondent(s)with the cost of repairs incurred by the County,the costs of prosecution incurred by the County and any fines Ordered in this matter. ( ) The Respondent(s)were in violation of the MONROE COUNTY Code(s)as fully set forth in the Notice of Violation/Notice of Hearing filed in this case and did not come into compliance on or before THE COMPLIANCE DATE but are now in compliance.The Respondents)shalt pay the total amount of cost and/or fines($ 1 to Mdonme County Code Compliance within thirty(30)days of this Order. (✓) T rrIP�J_�fo f fi1 S'4_ill Of T&/gaey AW 1— IJ aZ z& 44U.fi/�i'7� ,�. T n !P OA ar 04re. 'tr d Me res nih-q 411 7,aw4.Aver must- .4e Aw'&d on Pr de,+k.•-. in the event of nonpayment of fines andiaYb osts Imposed on Respondent(s),a certified copy of this Order may be recorded to the public records and shall thereafter consthute a lien against the lard on which the violation or violations exist and upon any other real or personal property owned by the violator.The County may Institute foreclosure proceedings If the lien remains unpaid for three months and/or may sue to recover money judgment for the amount of the lien plus accrued Interest.Please make checks payable to Monroe County Cade Compliance and mail to:Monroe County Code Compliance,Attn:Office of the Liaison,2798 Overseas Hwy,Suite 339,Marathon,FL 33050. IT IS S RESPONSIBILITY 70 REQUEST A REINSPECTION0 DETERMINE WHETHER H ERTY IS COMPLIANCE 453-8 THE UPPER KEYS iN%2W2s/0 FOR THE NOBLE KEYS:(33051292•d4955 FOR THE LOWER KEYS. DATED this Q� W day of DOop IN3689 John G.Vs ningham,Special gistrate 3kO 2594 PgN 895 Page i of 2 FINAL ORDER PAGE 2 CASE NUMBER: CE12070048 Respondent(s)mailing address of record with the Monroe County Property Appraiser's Office: CASTANEDA JUAN CARLOS 108 OLD FASHION RD TAVERNIER,FL 33070 Doeq 1903689 8kN 2594 P90 896 Location of Subject Property: 108 OLD FASHION ROAD KEY LARGO, FL 33037 RE NUMBER: 00482800000000 APPEAL PROCEDURES Respondent(s)shall have 30 days from the date of the foregoing Order of the Special Magistrate to appeal said Order by filing a Notice of Appeal, signed by the Respondent(s). ANY AGGRIEVED PARTY, INCLUDING MONROE COUNTY, MAY HAVE APPELLATE RIGHTS WITH REGARD TO THIS ORDER PURSUANT TO SECTION 162.11, FLORIDA STATUTES. ANY SUCH APPEAL WILL BE LIMITED TO APPELLATE REVIEW OF THE RECORD CREATED BEFORE THE SPECIAL MAGISTRATE. ANY APPEAL MUST BE FILED WITH CIRCUIT COURT WITHIN 30 DAYS OF THE EXECUTION OF THIS ORDER. CERTIFICATE OF ORDER I he ,:by that this is a true and correct copy of the above Order. Nicole M. Petrick,Liaison CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of this Order has been furnished to the Respondent(s) via hand delivery / first class U.S. mail to Respondent(s) address of record with the Monroe County Property A raiser's Office as referenced above and/or Authorized Representative on this Sr day of (JAhgg,_,20 IQ . Nicole M. Petrick,Liaison MONROE COUNTY PAGE 2 of 2 OFFICIAL RECORDS IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT, IN AND FOR MONROE COUNTY, FLORIDA CIVIL DIVISION WELLS FARGO BANK,N.A.,AS TRUSTEE FOR CASE NO,:442009CA000728AO01PK THE HOLDERS OF THE BEAR STEARNS ARM TRUST,MORTGAGE PASS-THROUGH Doan 1976745 94/16/2014 12:02PM CERTIFICATES, SERIES 2007-3 Filed g Recorded In Official Records of Plaintiff, MONROE COUNTY ANY WEAVILIN VS. JUAN CARLOS CASTANEDA,et at., DoaN 1976743 Defendants., 9kp 2879 Pon 1735 FINAL JUDGMENT OF FORECLOSURE THIS ACTION was heard before the Court at Trial on February 6,2014. On the evidence presented, IT IS ORDERED AND ADJUDGED that: 1. The Plaintiff,WELLS FARGO BANK,N.A.,AS TRUSTEE FOR THE HOLDERS OF THE BEAR STEARNS ARM TRUST,MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-3, is due: 2. Unpaid Principal $2,500 000.00 Per diem interest at 6.125%from 07/01/2008 to 02/06/2014 $712,182.69 Escrow Advances: $31,473.61 CountyTaos 2008 $19,516.95 Gourd Tax:2009 $21,038.19 Count Tax:2010 $19 034.96 CountyTax:2011 262.18 Coun $18, Tax:2012 62. Count $18 1 Tax: ,23$162. Flood Insurance:2007 $4,228.2 Flood insurance Credit:2008 $5 903.81 Flood Insurance:2009 $5,903.91 Flood Insurance:2010 $6,164.38 Flood Insurance:2011 $6,011.25 Flood Insurance:2012 $480 $4 0 3.60 Flood tn , surance:2013 3 Hazard Insurance:2007 ,6 4 Hazard Insurance Credit 2007 ($$5 5,3 .78 Hazard Insurance:2008 524.99 .49 Hazard Insurance Credit:2008 $13° Hazard Insurance:2009 $22,532.06 Hazard insurance:2010 $221532.05 Hazard Insurance:2011 $31,438.47 Hazard Insurance:2012 F26,929.41 Hazard Insurance:2013 $54,949'43 Escrcw Refund:2012 $14,298.29 Fee Due Advances: $60 00 Property,Ins 'on Fees: 2008 Pro a Ins ection Fees:2009 $180.00 Pro a Inspection Fees:20110 $75.00 Property Inspection Fees:2011 $90.00 Pro ins action Fees:2012 $22.70 Property Inspection Fees:2013 $139.85 12_001417112-001417-IICASTANEDAIODIJan 31,20141 'r✓ w,Arr Property Inspections Fees:2014 $11.35 HOAfees '� Subtotal $3,678 680.38 $ Foreclosure Attorne $3229.00 229 s Fees: , 0 Litigation Attome s Fees: Foreclosure Costs: Title Search Costs $250,0f] TOTAL $3,682,734.30 Doc'q 1976749 SkN 2679 P90 1736 that shall bear interest from this date forward at the prevailing rate. 2, Lien on Property. Plaintiff, whose address is 8742 Lucent Blvd., Suite 300, Highlands Ranch, CO 130129, holds a first-mortgage lien for the total sum superior to all claims or estates of DefendanXs), on the following described property in Monroe County, Florida: LOTS 7 AND 8,IN BLOCK 2, OF TAVENIER OCEAN SHORES,ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 4y AT PAGE 112, OF THE PUBLIC RECORDS OF MONROE COUNTY,FLORIDA. iog D19 L4AP Property Address:108 OLD FASHION RD,TAVERNIER, FL 33070-0000 If the grand total amount with interest at the rate described In Paragraph 1 and all costs accrued subsequent to this judgment are of paid, the Clerk of the Court shall sell the subject property at public sale on l to the highest bidder for case, except as prescribed in Paragraph 4, at the Front or the onroe County Courthouse, Lester Building, 500 Whitehead Street, Key West, FL 33040, in accordance with section 45.031, Florida Statutes, using the following method: �,/ at the address descn'bed above beginning at 11:00AM on the prescribed date. 3. Cost. Plaintiff shall advance all subsequent costs of this action and shall be reimbursed for them by the Clerk if Plainfrff is not the purchaser of the property for sale, provided, however that the purchaser of the property for sale shall be responsible for the documentary stamps payable on the certificate of We. If PlalnUff its the purchaser,the clerk shall credit Plaintiffs bid with the sum with interest and costs accruing subsequent to this judgment or such part of it,as is necessary to pay the bid in full. 4. Right of Redemption. On filing of the Certificate of Sale, Defendant(s)and all persons claiming under or against Defendant(s) since the filing of the Notice of Lis Pendens shall be foreclosed of all estate or claim in the property, except as to claims or rights under chapter 718 or chapter 720, Florida Statutes, if any. Upon the filing of the Certificate of Title, the person named on the Certificate of Title shall be let into possession of the property. 5. Distribution of Proceeds. On filing the Certificate of Title, the Clerk shall distribute the proceeds of the sale, so far as they are sufficient, by paying:first,all of the Plaintiffs costs;second, documentary stamps affixed to the Certificate;third, Plaintiffs attorneys'fees;fourth, the total sum due to the Plaintiff;, less the items paid, plus interest at the rate prescribed in paragraph 1 from this date to date of the sale;and by retaining any remaining amount pending the further order of this court. 6. Assignment of Judgment. The Plalnfrff may assign the Judgment and credit bid by the filing of an assignment without further Order of the Court. 7. Jurisdiction Retained. The Court retains jurisdiction of this action to enter further orders that are proper, iincluding, without limitation, Orders authorizing writs of possession and an award of attorneys fees,and to enter deficiency Judgments if the borrower has not been discharged in bankruptcy. IMP'#12-0014l7/12-401417-1/CASTANEDA/OD/Jan 31.2014) 8. NOTICE PURSUANT TO AMENDMENT TO SECTION,45.031,FLA.STt20061 IF THIS PROPERTY IS SOLD AT PUBLIC AUCTION THERE MAY BE ADDITIONAL MONEY FROM THE SALE AFTER PAYMENT OF PERSONS WHO ARE ENTITLED TO BE PAID FROM THE SALE_PROCEEDS PURSUANT TO THE FINAL JUDGMENT. IF YOU ARE�i7Dt ITE LIEN HOLDER CLAIMING A RIGHT TO FUNDS REMAINING AFTER THE SALE YOU MUST FILE A CLA114 WITH THE CLERK NO LATER THAN SIXTY(801 DAYS AFTER THE SALE. IF YOU FAIL TO FILE CLAIM,YOU WILL NOT BE ENTITLED TO ANY REMAINING FUNDS. IF YOU ARE THE PROPERTY OWNER, YOU MAY CLAIM THESE FUNDS YOURSELF. YOU ARE NOT e REQUIRED TO HAVE A LAWYER OR ANY OTHER REPRESENTATION AND YOU DO NOT HAVE TO ASSIGN YOUR RIGHTS TO ANYONE ELSE IN ORDER FOR YOU TO CLAIM ANY MONEY TO WHICH YOU -4W ARE ENTITLED PLEASE CHECK WITH THE CLERK OF THE COURT FOR YOUR COUNTY WITHIN (1011 a' DAYS AFTER THE SALE TO SEE IF THERE IS ADDITIONAL MONEY FROM THE FORECLOSURE SALE m THAT THE CLERK HAS IN THE REGISTRY OF THE COURT. ¢ IF YOU DECIDE TO SELL YOUR HOME OR HIRE SOMEONE TO HELP YOU CLAIM THE ADDITIONAL w MONEY YOU SHOULD READ VERY CAREFULLY ALL PAPERS YOU ARE REQUIRED TO SIGN, ASK SOMEONE ELSE, PREFERABLY AN ATTORNEY WHO IS NOT RELATED TO THE PERSON OFFERING TO HELP YOU TO MAKE SURE THAT YOU UNDERSTAND WHAT YOU ARE SIGNING AND THAT YOU ARE NOT TRANSFERRING YOUR PROPERTY OR THE EQUITY IN YOUR PROPERTY WITHOUT THE PROPER INFORMATION IF YOU CANNOT AFFORD TO PAY AN ATTORNEY,YOU MAY CONTACT A LOCAL LEGAL AID OFFICE TO SEE IF YOU QUALIFY FINANCIALLY FOR THEIR SERVICES. IF THEY CANNOT ASSIST YOU THEY MAY BE ABLE TO REFER YOU TO A LOCAL BAR REFERRAL AGENCY OR SUGGEST OTHER OPTIONS. IF YOU CHOOSE TO CONTACT A LOCAL LEGAL AID OFFICE,YOU SHOULD DO AS SOON AS POSSIBLE AFTER RECEIPT OF THIS NOTICE. („�� DONE AND ORDERED in MONROE County, Florida, this 7 / .day of 2014. ircuit Judge Publish in THE KEY WEST CITIZENS Copies furnished to: Millennium Partners 14750 NW 771h Court Suite 303 Miami Lakes, FL 33016 service@mlllenniumpartners.net All parties listed on the attached Service List. IMP#12-001417/12-001417-1/CASTANEDAIOD/Jan 31,2014] SERVICE LIST Case No.: 442009CA000728A001 PK MORTGAGE ELECTRONIC REGISTRATION SYSTEM, INC.AS NOMINEE FOR CITIBANK,FSB C/O CT CORPORATION SYSTEMS, INC. 1200 SOUTH PINE.ISLAND ROAD,SUITE 250 PLANTATION, FL 33324 /COCONUT GROVE BANK 2701 S BAYSHORE DRIVE MIAMI, FL 33133 FERDIE AND LONES, CHARTED Adverse Attorney for JUAN CARLOS CASTANEDA and JEANETTE CASTANEDA 717 PONCE DE LEON BLVD STE 223 CORAL GABLES, FL 33134 8kpn269767445 1738 Iawoffice@ferdieandlones.com MONROE COUNTY OFFICIAL RECORDS IMP#12-001417/12-001417-1/CASTANEDA/OD/Jan 31,20141 IN THE CIRCUIT COURT OF THE 16T11 JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY, FLORIDA CIVIL DIVISION MONROE COUNTY, a political subdivision of the State of Florida, q44P Case No. Plaintiff, Doc# 1853510 19/19/2013 1:03PM F 10 & Recorded !n Off a Re rds of �. V. l lNROE COUNTY 21 aiLit �s JUAN CARLOS CASTANEDA, _ " Defendant. c` Doan 1833510 Bkq 2633 PgN 2273 NOTICE OF LIS PENDENS n TO: DEFENDANT JUAN CARLOS CASTANEDA and ALL OTHERS WHOM IT MAY CONCERN: YOU ARE NOTIFIED of the institution of this action by Plaintiff against you seeking attachment of the following property in Monroe County, Florida: Lots 7-8, Block 2, of TAVERNIER OCEAN SHORES PLAT, according to the Plat thereof, as recorded in Plat Book 4, Page 112 of the Public Records of Monroe County, Florida DATED on thisQ� day of QC44<I- , 2013. Steven T. Williams FBN: 740101 Assistant County Attomey Monroe County Attorney's Office PO Box 1026 Key West, FL 33041-1026 (305)289-2526— Phone (305)289-2858— Fax Attorney for the Plaintiff MONROE COUNTY OFFICIAL RECORDS IN THE CIRCUIT COURT OF THE SIXTEENTH JUDICIAL CIRCUIT IN AND FOR MONROE COUNTY,FLORIDA CIVIL DIVISION MONROE COUNTY, a political subdivision of the State of Florida, Plaintiff, V. Case No.: 13- CA - q�V-r JUAN CARLOS CASTANEDA, Defendant. VERIFIED COMPLAINT FOR INJUNCTION AND FORECLOSURE COMES NOW, the Plaintiff, Monroe County, Florida (hereinafter "County") and in support of its Verified Complaint for Injunction and Foreclosure against Defendant Juan Carlos Castaneda(hereinafter"Defendant"and"Owner")would state as follows: I. Plaintiff Monroe County, is a political subdivision of the State of Florida. 2. Owner is an individual residing at 2210 SW 89h Court, Miami, FL 33165, and owns property located at 108 Old Fashion Road, Tavernier, Key Largo, Monroe County, Florida. 3. This is an action concerning real property located at 108 Old Fashion Road, Tavernier, Key Largo, Monroe County,Florida. 4. The subject property is located in an (IS) Improved Subdivision Land Use District where rentals for less than twenty-eight (28) days are prohibited per Monroe County Code Sections 130-83(b)and 134-1(k)(1). 5. The subject property has been repeatedly advertised and used as a short-term vacation rental under the names La Casa Grande, La Casa Grande Resort and The Falcon Estate. 6. On February 26, 2009, Monroe County first received a complaint regarding unapproved use and advertisement of the subject property as a short-term vacation rental for a period of less than 28 days. 7. On February 26, 2009, the Monroe County Code Compliance Department opened Code case CE 09030067 against the Owner. 8. On February 26, 2009, Code Compliance conducted a vacation rental inspection and found the subject property advertised for a period of less than 28 days on VRBO ("Vacation Rental By Owner") Listing#217911. (See attached Exhibit"A"). 9. On June 9, 2010, Code Compliance conducted a site inspection which revealed the subject property unlawfully rented as a short-term vacation rental for less than 28 days. 10. On November 16, 2010, Code Compliance conducted a vacation rental inspection and found the subject property advertised as a short-term vacation rental for less than 28 days on three (3) web sites: VRBO, Listing #217911; Villa4Vacation.com, Listing #446385; HomeAway.com, Listing#173152. (See attached Exhibit"B"). 11. On January 10, 2011, Code Compliance contacted Owner, explained the cited violations and attempted to guide Owner in reaching compliance with the County codes. 12. On August 30, 2011, Owner entered into a"Stipulation to code violation and for time to comply for first time offenses" agreement with Monroe County, agreeing to a one-time fine in the amount of $5,000 and to immediately cease and desist all vacation rental activity including the advertising and/or holding out of the property for any period of less than 28 days.(See attached Exhibit"C"). 13. On September 29,2011, Code case CE 09030067 was deemed compliant. 14. After numerous additional complaints from neighbors alleging continued short-term vacation rental use of the subject property, Code Compliance initiated an additional investigation which resulted in a Notice of Violation/Notice of Hearing initiating a new Code case CE 12070048 on October 21, 2011. 15. On January 4, 2012, Code Compliance conducted a vacation rental inspection and found the subject property advertised for a period of less than 28 days on www.GreatRentals.com Listing#173152. (See attached Exhibit"D"). 16. On February 13, 2012, Code Compliance conducted a site inspection which revealed tenants who invited County staff into the subject property to show several problems they experienced with the home's structure and provided County staff with a copy of their contract to rent the subject property for less than 28 days. (See attached Exhibit"E"). 17. On August 7, 2012, the Notice of Violation/Notice of Dearing issued pursuant to Code case CE 12070048 was served on Owner, citing Owner as a repeat violator for continued short-term vacation renting and advertising. 18. On September 27, 2012, a hearing was held which Owner attended with counsel, and a Special Magistrate found Owner in violation of Monroe County Code Sections 130-83(b) and 134-1(k)(1) for the use of the home as a short-term vacation rental and advertising the home as available for short-term vacation rental. 19. The Special Magistrate found the violations to be irreparable or irreversible and issued an Order that imposed a one-time fine in the amount of $15,000 and required Owner to immediately cease and desist of the rental use of the property. 20. The Special Magistrate set a compliance date of October 10, 2012, imposing fines in the amount of $2,000 per day ($1,000 per day per violation) beginning October 11, 2012, continuing until the Owner reached compliance with the Order by removing advertisements reflecting rentals of less than 28 days and ceasing to rent for less than 28 days. 21. As of August 5, 2013, the $15,000 one-time fine remains unpaid, the total amount of the lien filed pursuant to the Code cases was $610,000, and daily fine(s) in the amount of $2,000 per day continue to accrue. 22. Complaints from neighbors regarding the use of the subject property as a short-terns vacation rental for less than 28 days continue to be received as recently as July 18,2013. 23. There has been no effort on the part of Owner, who continues to advertise the subject property as a short-term vacation rental for less than 28 days with weekly rental rates of approximately $6,000 per week, to gain compliance with the County codes and the Special Magistrate's Order(See attached Exhibit"F"). Count 1: Iniunctive Relief 24. The County reincorporates the allegations of Paragraphs 1-23 of this Complaint as if fully set forth herein. 25, The conditions existing upon Owner's subject property are continuing in nature and Owner has failed to bring the property into compliance with Monroe County codes, despite repeated demands to do so. 26. The request for injunctive relief set forth in this Verified Complaint constitutes a valid exercise of the County's police power. 27. Where a governmental entity seeks an injunction in order to enforce its police powers, any alternative legal remedy is ignored and irreparable harm is presumed. 28. The County has a strong public interest in ensuring against an unfair bed tax burden upon motel and hotel owners and the diversion of scarce residential housing to short-term vacation rental use. WHEREFORE,the County requests judgment against Defendant on this count for: A. A temporary and permanent injunction, without bond, mandating that Defendant cure all of the violations described in Paragraphs 12, 14, 18, 19,20, 21, 23, and 28 within ninety(90)days from the date of the injunction; and, B. Thereafter keep the property in compliance with the Monroe County Code. Count II: Foreclosure 29.The County reincorporates the allegations set forth in paragraphs 1-23 as if the same were fully set forth herein. 30. Pursuant to §162.09(3), Florida Statutes, the County is entitled to foreclose upon the liens imposed as a result of Owner's code violations. 31. All conditions precedent to filing this action have been satisfied. 32.Under Section §162.10, Florida Statutes, the County is entitled to recover all costs incurred, including a reasonable attorney's fee, in successfully prosecuting this action. WHEREFORE,Plaintiff demands: A. Judgment against Defendant foreclosing the liens, and, B. A deficiency judgment, if the proceeds of the sale are insufficient to pay Plaintiff's claim,including attorney's fees and costs; and C. Such fi -ther relief as this court deems just and proper. Count III:Money Judgment 33. The County reincorporates the allegations set forth in paragraphs 1-23 as if the same were fully set forth herein. 34. Pursuant to §162.09(3) and §162.125, Florida Statutes, the County is entitled to a money judgment for unpaid fines imposed by the Special Magistrate. 35.As of August 5, 2013, in Code Enforcement Case No.: 12070048, the fine totals $610,000. The fines are accruing at$2.000 per day. 36. Pursuant to §162.10, Florida Statutes, the County is entitled to recover all costs incurred, including a reasonable attorney's fee,in successfully prosecuting this action. WHEREFORE, Plaintiff demands Judgment for damages for the total amount owed as of the date of Final Judgment, including all costs and attorney's fees and for all other relief just and proper in the premises. Count IV: Writ of Execution 37.The County reincorporates the allegations set forth in paragraphs 1-22 as if the same were fully set forth herein. 38. Pursuant to §162.09(3),Florida Statutes,the County petitions this Honorable Court to issue a Writ of Execution as an alternate remedy to collect the unpaid code enforcement fines and costs owed by the Defendant. WHEREFORE, the County respectfully requests that the Court enter a Writ of Execution against the property of Defendant. VERIFICATION Under penalties of perjury, I declare that I have read the foregoing Verified Complaint and that the facts stated there are true to the best of my knowledge. Respectfully submitted, Steven T. Williams Bar No. 0740101 Docq 1966237 02/23/2014 2:51PN Filed & Recorded in Official Records of MONROE COUNTY AMY HEAVILIN MONROE COUNTY, FLORIDA OFFICE OF THE CLERK OF THE CIRCUIT COURT&COMPTROLLER. WARRANT FOR COLLECTION OF DELINQUENT TOURIST DEVELOPMENT TAX& TOURIST IMPACT TAX DocN 1966237 BkN 2668 P9N 907 MONROE COUNTY, FLORIDA TO: ALL AND SINGULAR THE CLERKS OF THE CIRCUIT COURTS,AND ALL AND SINGULAR THE SHERIFFS OF THE STATE OF FLORIDA WHEREAS,under Sec. 125.0104,Florida Statutes, Chapter 212,Florida Statutes and Chap. 23, Monroe County Code, is indebted to Monroe County, State of Florida,in the following amounts: Tax $46,440.00 Penalty 21,930.00 Interest 4,755.76 Total 73,125.76 Filing Fees 20.00 Grand Total $73,145.76 WHEREAS, said total amount due and unpaid is now delinquent and subject to collection as provided by County ordinance and law; and WHEREAS, under the law and ordinance it is the duty of the Clerk of the Court, Monroe County, State of Florida, to issue a warrant for the collection of the delinquent taxes, together with penalties, interest and costs of collection; NOW,THEREFORE, you and each of you are hereby commanded to levy upon and sell the real or personal property,or both,of the named taxpayer sufficient to pay the total amount due for which Juan Carlos&Jeannette Castaneda,108 Old Fashion Road,Tavernier,Florida is liable to the said Monroe County,Florida,together with the costs of executing this warrant and your proceedings thereon,and that you make return of this warrant to me, Clerk of the Court of Monroe County,Florida,at my office in the Justice Center, Key West, Florida,when satisfied,and pay me the money which you collect thereon. WITNESS my hand and official seal in this City of Key West, Monroe County, Florida, this 21 st day of January,2014. Amy Heavilin,CPA ` Il.d.l, ,::: ;..'°y Clerk of the Circuit Court&Comptroller .i Monroe Cowity, Florida (SEAL) ` = .,,: BY. Bert erez, Dep derf MONROE COUNTY OFFICIAL RECORDS 4 . f Case 1:08-cr-20442-FAM 'Document 99 Entered on FLSD Docr,_. 11/24/2008 Page 1 of 2 Co UNITED STATES DISTRICT COURT a�w IR SOUTHERN DISTRICT OF FLORIDA L .C3 BE a_1 7 CASE NO. 08-20442-CR-MORENO y� UNITED STATES OF AMERICA, Certified to he - +r:le end �»a corrrci c,p r ,0 1 .;7; tale N oz Steven M. L�ri ;aore, vs. � - r t ,rr e,r is Gf u w a} JUAN CARLOS CASTENADA, m :o C2 [ u rn Ge c) atp D ty C er k to Defendant. ,� ODW u M' a°LL� ORDER OF FORFEITURE THIS CAUSE is before the Court upon oral motion of the United States,at sentencing, for forfeiture in accordance with the Consent to Forfeiture and the Flea Agreement entered into by the parties.Having reviewed the record,and for good cause shown,it is hereby ORDERED that: 1. All right,title and interest of defendant, JUAN CARLOS CASTENADA,in 50%of a the proceeds derived from the sale of the real property located at 108 Old Fashion Road,Tavernier, n. Florida 33070,is hereby forfeited to the United States ofAmerica pursuant to Title 18,United States N O Y Code, Section 982 and the procedures outlined at Title 21,United States Code, Section 853, o,n 2. The United States Marshal or any duly authorized law enforcement official,shall take such actions as are necessary to complete the forfeiture of the property identified herein above as forfeited under this order pursuant to Title 21, United States Code, Section 853(g), 3, The United States shall cause to be published at least once, in accordance with due process considerations, notice of this Order as required by Title 21, United States Code, Section 853(n)(6). The notice shall state that any person,other than Defendant,having or claiming a legal_ interest in the property ordered forfeited by this Order must file a petition with the Court within thirty Case 1:08-cr-20442-FAM -Document 99 Entered on FLSD DocrwE 11/24/2008 Page 2 of 2 (30)days of the final publication of the notice or receipt of actual notice,whichever is earlier;that the petition shall be for a hearing to adjudicate the validity of the petitioner's alleged interest in the property;and that the petition shall be signed by the petitioner under penalty of perjury,shall set forth the nature and extent of the petitioner's right,title and interest in the forfeited property and shall set of W. forth any additional facts supporting the petitioner's claim and the relief sought. C O M At 4. The United States may provide,to the extent practicable,direct written notice to any W N� person known to have an alleged interest in the property that is subject of the Order of Forfeiture, a°� in addition to the published notice. It is further ORDERED that upon adjudication of all third-party interests,this Court will enter a Final Order of Forfeiture pursuant to Title 21, United States Code, Section 853(n)in which all interests will be addressed. If no claims are filed within 30 days of the final publication or receipt of actual notice, whichever is earlier,then pursuant to Title 21, United States Code, Section 853(n)(7), this Order shall be deemed a Final Order of Forfeiture, and the United States Marshal or any duly authorized law enforcement official,shall dispose of the property forfeited hereunder according to law. DONE AND ORDERED in Miami, Florida, this day of November, 2008. CO ORENO uNrrEBr§TATEs DISTRICT JUDGE MONROE COUNTY OFFICIAL RECORDS Authorization No. DEPARTMENT OF JUSTICE For Optional Use by Recording Ofiicc: NOTICE OF LIEN FOR FINE Docq 1$77710 04/10/2012 9:14AM AND/OR RESTITUTION FMONROERCOUNTY in official KOLHAGE of IMPOSED PURSUANT TO THE ANTI-TERRORISM AND EFFECTIVE DocN 187 710 10 DEATH PENALTY ACT OF 1996 United States Attorneys Office SOUTHERN DISTRICT OF FLORIDA Notice is hereby given of a lien against the property of the defendant named below. Pursuant to Title 18,United States Code, Section 3613(c), a fine or an order of restitution imposed pursuant to the provisions of subchapter C of chapter 227 is a lien in favor of the United States upon all property belonging to the person fined or ordered to pay restitution. Pursuant to § 3613(d)a notice of lien shall be considered a notice of lien for taxes for the purposes of any State or local law providing for the filing of a tax lien. The lien arises at the time of the entry ofludgment and continues until the liability is satisfied,remitted, or set aside, or until it becomes unenforceable pursuant'to § 3613(b). Name of Defendant: JUAN CASTANEDA Social Security Number:ENNEMOM Date of Birth: XX/1961 Amount of FinelRestitution: $30,000.00 Court Imposing Judgment: U.S.DISTRICT COURT, SDFL Court Number: 07-20565-CR-COHN Date of Judgment: MARCH 28,2008 *PLUS STATUTORY INTEREST* If payment becomes past due,possible penalties totaling 25 percent of the.principal amount past due may arise. 18 U.S.C. § 3612(g). IMPORTANT RELEASE INFORMATION--With respect to the lien listed above, this notice shall operate as a certificate of release pursuant to 18 U.S.C. § 3613(b)by operation of law but no later than JUNE 28,2033 Place of Filing: MONROE COUNTY,FLORIDA This notice was prepared at MIAMI, on this,the �: day�`- '2012. Signature This Instrument Prepared By: Lesley Pasquet U.S. Attorney's Office Financial Litigation Unit 99 N. E. 4th Street Miami, Florida 33132 (305) 961-9193 MONROE COUNTY OFFICIAL RECORDS OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY COMMITMENT Schedule A Fund File Number:38 2014-000708 Effective Date: Agent's File Reference: Premium: July 9,2014 @ 11:00 PM 14-006 1. Policy or Policies to be issued: Proposed Amount of Insurance: OWNER'S:ALTA Owner's Policy(06/17/06).(With Florida Modifications) $1,500,000.00 Proposed Insured: HARLEY V.STOCK and ROBIN E.STOCK MORTGAGEE:ALTA Loan Policy(06/17/06)..(With Florida Modifications) $1,200,000.00 Proposed Insured: To Be Determined MORTGAGEE: 2. The estate or interest in the Land described or referred to in this Commitment is FEE SIMPLE. 3. Title to the FEE SIMPLE estate or interest in the Land is at the Effective Date vested in: JUAN CARLOS CASTANEDA 4. The Land referred to in this Commitment is described as follows: Lots 7 and 8,Block 2,TAVERNIE.R OCEAN SHORES,according to the plat thereof as recorded in Plat Book 4,Page 112,Public Records of Monroe County, Florida. OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY 400 Second Avenue South,Minneapolis,MN 55401,(612) 371-1111 Issuing Agent: Agent No.: 1258000 Laura F Morgan 1322 Northeast 4th Avenue Suite C Ft Lauderdale,FL 33304 Agent's Signat e Laura F Morgd. arm CF&SCH.-A(rev.12/10)CWith Florida Modifications) Page 1 of 5 OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY COMMITMENT Schedule B-I Fund File Number: Agent's File Reference: 38-2014-000708 14-006 I. The following are the requirements to be complied with: l. Payment of the full consideration to,or for the account of,the grantors or mortgagors. 2. Instruments creating the estate or interest to be insured which must be executed,delivered and filed for record: A. Warranty Deed from JUAN CARLOS CASTANEDA,joined by spouse,if married,or non-homestead language,to the proposed purchaser(s). 3. The Company has no liability under this commitment until an endorsement is issued stating the names of the proposed insured.Once the proper names are provided,The Company reserves the right to make additional requirements and/or exceptions. 4. The Company has no liability under this commitment until an endorsement is issued stating the amount of the proposed policy.No title policy may be issued in an amount greater than$1,000,000.00 without specific Underwriting approval. 5. Satisfaction of the mortgage from JUAN CARLOS CASTANEDA and JEANNETTE CASTANEDA,husband and wife to Mortgage Electronic Registration Systems,Inc.,as nominee for,dated January 26,2007,and recorded in O.R. Book 2272,Page 1075,and assigned by assignment filed in O.R.Book 2426,Page 1726,Public Records of Monroe County,Florida.O.R.Book 2556,Page 2378,further assigned to Wells Fargo Bank,N.A.,as Trustee for the Holders of the Structured Asset Mortgage Investments II Inc.,Bear Stearns Arm Trust,Mortgage Pass-Through Certificates, Series 2007-3 in O.R.Book 2661,Page 26,Public Records of Monroe County,Florida,return of the original note marked cancelled. 6. Record dismissal of court action with prejudice and discharge of Lis Pendens recorded in O.R.Book 2424,Page 673, Vacation of the Final Judgment of Foreclosure recorded in O.R.Book 2679,Page 1735,in that certain Case No.44 2009 CA 728A001PK in the Circuit Court of Monroe County,Florida.For involuntary dismissal,the appeal period must expire. 7. Satisfaction of the Final Order in Case NO CE .120070048,Code Compliance Monroe County,Florida against JUAN CARLOS CASTANEDA,or a similar name,certified copies of which are recorded in the following O.R.Books and Pages: O.R.Book 2594,Page 895,Public Records of Monroe County,Florida. 8. Satisfaction of the Final Order in Case NO CE 09030067,Code Enforcement Monroe County,Florida against JUAN CARLOS CASTANEDA,or a similar name,certified copies of which are recorded in the following O.R.Books and Pages:O.R.Book 2546,Page 165,Public Records of Monroe County,Florida. 9. Affidavit to be executed by JUAN CARLOS CASTANEDA stating: 1)There are no matters pending against the affiant that could give rise to a lien that would attach to the property between July 16,2014 and the recording of the interest to be insured. 2)That the affiant(s)have not and will not execute any instruments that would adversely affect the interest to be insured. 10. Closing funds are to be disbursed by or at the direction of the Title Agent identified at bottom of Schedule A. 11. Affidavit from the owner of the subject property,or some other person having actual knowledge,establishing that no person other than the owner is in possession. 12. Title Agent is to record the insured instruments as soon as possible after closing. 13. A survey meeting The f und's Title Notes requirements must he furnished. If such survey reveals any encroachments, overlaps,boundary line disputes,or other adverse matters,they will appear as exceptions in the policy to be issued based upon this commitment. 14. In the event that a foreclosure action has been commenced,requirements must be made for the dismissal of the lawsuit, with prejudice,and discharge of the lis pendens.The short-sale lender's payoff letter must include all costs and fees associated with the foreclosure action in addition to the information required in#6 above. Form CFG-SCH.-B-I(rev.12/10) Page 2 of 5 OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY COMMITMENT Schedule B-I (Continued) Fund File Number: Agent's File Reference: 38-2014-000708 14-006 15. Record dismissal of court action with prejudice and discharge of Lis Pendens recorded in O.R.Book 2653,Page 2273, in that certain Case No. 13 CA 944 P in the Circuit Court of Monroe County,Florida.For involuntary dismissal,the appeal period must expire. 16. Satisfaction of the Tax Warrant against JUAN CARLOS CASTANEDA,or a similar name,certified copies of which are recorded in the following O.R.Books and Pages:O.R.Book 2668,Page 907 Public Records of Monroe County, Florida. 17. Record satisfaction,release or credible proof of non-identity containing the legal description of the subject property and relating to the following Notice of Lien against the name ofJUAN CARLOS CASTANEDA recorded in the following Official Records: O.R.Book 2564,Page 10,Public Records of Monroe County,Florida. 18. The Company reserves the right to make additional requirements. 19. Note: Taxes for the year 2013 which have been paid under receipt number 112-13-00009771,on November 25,2013, Alternate Key Number 1592412,the gross amount being,$18,209.89. 20. A search commencing with the effective date of this commitment must be performed at or shortly prior to the closing of this transaction. if this search reveals a title defect or other objectionable matters,an endorsement will be issued requiring that this defect or objection be cleared on or before closing. Form CF&SCHA-I continued(rev.05/10) Page 3 or 5 OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY COMMITMENT Schedule B-H Fund File Number: Agent's File Reference: 38-2014-000708 14-006 IT, Schedule B of the Policy or Policies to be issued will contain exceptions to the following matters unless the same are disposed of to the satisfaction of the Company: 1. Defects,liens,encumbrances,adverse claims or other matters,if any,created,first appearing in the Public Records or attaching subsequent to the Effective Date hereof but prior to the date the Proposed Insured acquires for value of record the estate or interest or Mortgage thereon covered by this Commitment. 2.a.General or special taxes and assessments required to be paid in the year(s)2014 and subsequent years. b.Rights or claims of parties in possession not recorded in by the Public Records. e. Any encroachment, encumbrance, violation, variation. or adverse circumstance that would be disclosed by an inspection or an accurate and complete land survey of the Land and inspection of the Land. d.Easements,or claims of easements,not recorded in the Public Records. e.Any lien,or right to a lien,for services,labor,or material furnished,imposed by law and not recorded in the Public Records. 3. Any Owner Policy issued pursuant hereto will contain under Schedule B the following exception: Any adverse ownership claim by the State of Florida by right of sovereignty to any,portion of the Lands insured hereunder, including submerged,filled and artificially exposed lands,and lands accreted to such lands. 4. Rights of the lessees under unrecorded leases. 5. All matters contained on the Plat of Tavernier Ocean Shores,as recorded in Plat Book 4,Page 112,Public Records of Monroe County,Florida 6. Some counties and municipalities including,but not limited to,Miami-Dade County and the Cities of Coral Springs, Deerfield Beach,Margate,Miami Gardens,North Lauderdale and Treasure Island,have enacted ordinances imposing upon lenders with properties in foreclosure the duty of maintaining the properties until they are resold.Other local governments will probably follow.Enforcement mechanisms vary but may include required registration of the property prior to or during foreclosure,inspections and certifications of condition by local authorities or licensed professionals,compliance with miscellaneous local codes,mandatory inspection or processing fees,certificates of use or re-occupancy,and financial penalties for non-compliance. WhUe The Company will continue to disclose recorded notices of non-compliance and will include requirements or exceptions as appropriate on examined Fund or Old Republic National Title Insurance Company products,certificates of use or re-occupancy requirements lie outside of title policy coverage.Nevertheless,Title Agents are cautioned to determine whether any such ordinance(s)exist(s)for the County or municipality in which the subject property is situated and to follow the requirements thereof as part of their closing preparation and procedure in order to protect clients and to avoid possible non-compliance with lender closing instructions. 7. State Law under Chapter 76-190 and Chapter 22F-8.02 of the Florida Administrative Code for Land Planning for the Florida Keys Area of Critical State Concern,recorded in O.R.Book 668,Page 43,Public Records of Monroe County, Florida_ 8. Unity of Title recorded in O.R. Book 2154,Page 2329,Publ is Records of Monroe County,Florida. 9. Riparian and littoral rights are not insured. 10. Those portions of the property herein described being artificially filled in land in what was formerly navigable waters, are subject to the right of the United States Government arising by reason of the United States Government control over navigable waters in the interest of navigation and commerce. 11. The rights, if any,of public to use as a public beach or recreation area any part of the land lying or formerly lying between the body of water abutting the subject property and the natural line of vegetation,bluff,extreme Ihigh-water Form CF&SCHA-II(rev.12110) Page 4 of 5 OLD REPUBLIC NATIONAL TITLE INSURANCE COMPANY COMMITMENT Schedule B-II (Continued) Fund File Number: Agent's File Reference: 38-2014-000708 14-006 line or other apparent boundary lines separating the publicly used area from the upland private area,as it may have existed prior to the construction,if any,of sea wall or bulkhead thereon. Form CH-SCH:&II continued(rev.05/10) Page 5 of 5 N THE CIRCUIT COURT .4ONROE COUNTY,FLORIDA ' 'IVIL DIVISION ase No. �� " _ Doe* 1752329 07/27/2009 11:03AII WELLS FARGO BANK,N.A. AS TRUSTEE FOR Piled 8 Recorded in Official Records of THE HOLDERS OF BEAR SfEARNS ARM TRUST, MONROE COUNTY DANNY L. KGLHAGE MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2007-3 Plaintiff. Doe* 1752329 Ok* 2424 PO* 673 VS. JUAN CARLOS CASTANEDA AKA JUAN C. CASTANEDA,JEANNETTE CASTANEDA; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.;COCONUT GROVE.BANK,and UNKNOWN TENANTSIOWNERS, Defendants. NOTICE OF LIS PENDENS 'O DEFENDANT(S); UAN CARLOS CASTANEDA AKA JUAN C.CASTANEDA EANNETTE CASTANEDA; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.;COCONUT GROVE BANK JNKNOWN TENANTS/OWNERS tLL OTHERS TO WHOM IT MAY CONCERN You are notified of the institution of this action by Plaintiff against you seeking to foreclose a mortgage encumbering the following cal property in Monroe County,Florida: .OTS 7 AND 8,1N BLOCK 2,OF TAVENIER OCEAN SHORES,ACCORDING TO THE PLAT THEREOF, ►S RECORDED IN PLAT BOOK 4,AT PAGE 112,OF THE PUBLIC RECORDS OF MONROE COUNTY,FLORIDA. pith a street address of 108 OLD FASHION RD,TAVERNIER,FL 33070. DATED: July 16,2009. Edward B.Pritcl d ' Florida Bar No.:71 76 Kass,Shuler,Sal on,Spector, ' Foyle&Singer,P.A. - P.O.Box 800 y 1505 N.Florida Ave. p. Tampa,FL 33601 (813) 229-0900 ext 1309 Attorneys for Plaintiff 86750.093824A/PJ8 MONROE COUNTY OFFICIAL PUBLIC RECORD IN THE CIRCUIT COURT OF THE SIkTEENITH JUDICIAL CIRCUIT, IN AND FOR MONROE COUNTY,FLORIDA CIVIL DIVISION WELLS FARGO BANK,N.A.,AS TRUSTEE FOR CASE NO.:442009CA000728A001 PK THE HOLDERS OF THE BEAR STEARNS ARM TRUST,MORTGAGE PASS-THROUGH Doom 2976745 64/16/2024 12:02M CERTIFICATES,SERIES 2007-3 Filed & Recorded in Official Records of Plaintlff, MONROE COUNTY ANY HEAVILIIN , VS. JUAN CARLOS CASTANEDA,et aJ., Dec# 1975745 Defendants. 8kq 21679 Post 1735 FINAL JUDGMENT OF FORECLOSURE THIS ACTION was heard before the Court at Trial on February 6,2014. On the evidence presented,.IT IS ORDERED AND ADJUDGED that , 1. The Plaintiff,WELLS FARGO BANK,N A.,AS TRUSTEE FOR THE HOLDERS OF THE BEAR STEARNS ARM TRUST,MORTGAGE PASS THROUGH CERTIFICATES,SERIES 2007-3,is due: 2. Unpaid Principal $2 500 000.DO Per diem interest at 6.1250/6 from 07/01/2008 to 02/06/21114 $712.182.69 Escrow Advances: $31,473.61 Cou Tax:2008 $19,518.96 czu-rity Tar 2009 $21 038.19 Count Twc 2010 $19.034.96 County Tax:2011 $18,262.18 County Tax 2012 $18 202.13 do—unty Taw 2013 $10,668.29 Flood Insurance:2007 $4,224.24 Flood Insurance Credit:2008 $5 903.91 Flood Insurance:2009 $5.903.91 Flood Insurance:2010 $6.154.38 Flood Insurance:2011 $6.0`1125 Flood Insurance:2012 $4,603.50 Flood Insurance:2013 $42 680.43 Hazard insurance:2007 $5 354.78 Hazard Insurance Credit 2007 $34,881.49 Hazard Insurance:2008 $13,524.99 Hazard Insurance Credit 2008 $22 53206 Hazard Insurance:2009 $22,53205 Hazard insurance:2010 $31,438.47 Hazard Insurance_2011 $26 929 41 Hazard Insurance:2012 $54,949 Hazard Insurance:2013 $14 298.29 ,43 Escrow Refund:2012 Fee DueAdvances; Pro tns ection Fees:2008 $�'� Pr In ion Fees;2009 $180.W 75 Property Ins "on Fees:2010 90.g0 Property Inspection Fees:2011 $2 . 0 IPro Inspection Fees:2012 $22.70 Pro Inspection Fees;2013 $139.85 jmpo 12 001417112-0014i7-i/CASTANEDA/OWJan 31,20141 �y Mawr► Pro ins cdons Fees:2014 $11.35 HOA,fees $444.30 Subtotal $3 580.39 Foreclosure Attome s Fees: $676.00 L" ation Attome s Fees: $3 .00 Foreclosure Costs: $250.00 Title Search Costs TOTAL $3,582,71&A Dean 1976745 Ilk# 2679 Pg# 1736 that shall bear interest from this date fonaard at the prevailing rate. 2. Lien on Property. Plaintiff, whose address is 8742 lucent Blvd., Suite 300, Highlands Ranch, CO 80129, holds a first-mortgage lien for the total sum superior to all claims or estates of Defendant(s),on the foitmwing described property in Monroe County,Florida: LOTS 7 AND 8,IN BLOCK 2,OF TAVENIER OCEAN SHORES,ACCORDING TO THE PLAT THEREOF,AS RECORDED IN PLAT BOOK 4„AT PAGE 112, OF THE PUBLIC RECORDS OF MONROE COUNTY,FLORIDA. Property Address:108 OLD FASHION RD,TAVERNIER,FL 33070-0000 If the grand total amount with interest at the rate described in Paragraph 1 and all costs accrued subsequent to this judgment are of paid, the Clerk of the Court shall sell the subject property public e on Q' to the highest bidder for case, except as prescribed in Paragraph 4, at the Frazt ar the onroo County Courthouse, Lester Building, 500 Whitehead Street, Key West, FL 3304fi,in"rdance with section 45.031, Florida Statutes,using the following method: �,/ at the address descried above beginning at 11-.00AM on the prescribed date. 3. Cost.Plaintiff shall advance all subsequent costs of this action and shall be reimbursed for them by the Clerk If Plaintiff is not the purchaser of the property for sale, provided, however that the purchaser of the property for sale shalt be responsible for We documentary stamps payable on the certificate of due. if Plaintiff is the purchaser,the clerk shall credit Plaintiffs bid with the sum with Interest and costs accruing subsequent to this judgment,or such part of It.as is necessary to pay the bid in full. 4. Right of Redemption. an filing of the Certificate of Sale, Defendants)and all persons claiming under or against Defendent(s)since the filing of the Notice of Lis Pandens shall be'foreclosed of all estate or claim in the property,except as to claims or rights under chapter 718 or chapter 720, Mdda Statutes, If any. Upon the filing of the Certificate of Title,the person named on the Certificate of Ttle shall be het Into possession of the property. 5. Distribution of Proceeds. On filing the Certificate of Title,the Clerk shall distribute the proceeds of the sale,so far as they are sufficient, by paying:first,all of the Plaintiffs costs:second, documentary stamps affixed to the Certificate;third, Plaintiffs attorneys'fees:fourth,the total sum due to the Plaintiff,less the items paid, plus interest at the rate prescribed in paragraph 1 from this date to date of the sale;and by retaining any remaining amount pending the further order of this court. 6. Assignment of Judgment. The Plaintiff may assign the judgment and credit bid by the filing of an assignment without further Order of the Court. 7. Jurisdiction Retained. The Court retains jurisdiction of this action to enter further orders that are proper, including. without limitation, Orders authorizing writs of possession and an award of attorneys fees,and to enter deficiency judgments if the borrower has not been discharged in bankruptcy. IM'412-001417112-DO1417-1lCASTANEDAIOCWJan 31.20,141 a. NOTICE PURSUANT TO AMENDMENT TO SE ON 45.031 FLA.ST.2006 M THE I THIS P OPER IS SOP AT PUB LIC W AUCTION,THERE MAY O B�BE D OM�-E PhNONIEY O E DS PURSUANT TO THE f MAL JUDCGMF_NT IF YOU ARE A SUBORDI TE LI HO CLAJMING A RIGHT TO FUN REM LNG THE SALE.YOU MUST FILE A CLAIM WITH THE CLERK NO LATER THAN S1X7Y tl�l BAYS AFTER THE SALE, IF YOU FAIL TO FILE A CLAIM YOU WILL NOT BE ENTITLED TO ANY REMAINING_FUND_S_. My IF YOU ARE THE PROPERTY OWNER YOU MAY M THESE'FUNDS YOURSELF YOU E NOT �e REQUIRED TO HAVE A LAWYER OR ANY OTHER REPRESENTATION AND YOU DO NOT HAVE TO a� ASSIGN YOUR RICaHTS TO ANYONE ELSE IN ORDER FOR YOU TO CLAIM ANY MONEY TO WHICH YOUO1+m ARE ENTITLED. PLEASE CHECK WITH THE CLERKOF THECOURT O OUR COUNTI WITHIN 10 fD 4 DAYS AFTER THE SALE TO SEE IF THERE IS ADDITIONAL MONEY FROM THE FORECLOSURE SALEis v� THAT THE CLERK HAS IN THE REGISTRY OF THE COURT. IF YOU DECIDE TO SELL YOUR HOME OR HIRE SE TO HELP YOU CLAIM THE ADDITIONAL i OMEON MONEY YOU SHOUL R VERY AREFULLY ALL PAPERS YOU P RE U TO SIGN ASK -4 SO EO E L P LY AN ATT RNEY WHO IS NOT RELATEDO E PERS EKING TO H P YO T M S RE THAT YOU UNDERSTAND WHAT YOU A SIGNING AND THAT Ujig NOT TRANSFERRING Y R PROP OR THE E ITY IN YOUR PROPERTY OTT P PE. INF MO .IF YOU CANNO A d b O Y A OR Y U MAY CT LOCAL"LEGAL AID OFFICE TO SEE IF YOU QUAL�INANCIALLY FOR THEIR SERVICES IF ?HEY CANNOT"ASSIST YOU.THEY MAY BE ABLE TO REFER YOU TO A LOCAL BAR REFERRAL AGENCY OR SUGGEST OTC OPTIONS.IF YOU CHOOSE TO CONTACT A LOCAL G L AID OFFIC YOU SHOO D AS SOON AS POSSIBLE AFTER RECEIPT OF THIS NOTICE. (,� DONE AND ORDERED in MONROE County, Florida"- ircuit 7t - f 2014- .fudge Publish in THE KEY WEST CITIZENS Copies furnished to: Millennium Partners 14750 NW 77th Court Suite 303 Miami Lakes,FL 33016 service@,millennkimpartners.net All parties listed on the attached Service List. ''MP#12-00141TI12-001417-1JCASTANEDNOD/Jan 31,20141 SERVICE LIST Case No.: 442009CA00072BA00-1 PK /MORTGAGE ELECTRONIC REGISTRATION SYSTEM,INC.AS NOMINEE FOR CITIBANK, FSB CIO CT CORPORATION SYSTEMS, INC. 1200 SOUTH PINE ISLAND ROAD,SUITE 250 PLANTATION,FL 33324 ./COCONUT GROVE BANK 2701 S BAYSHORE DRIVE MIAMI, FL33133 FERDIE AND LONES,CHARTED Adverse Attorney for JUAN CARLOS CASTANEDA and JEANETTE CASTANEDA -fl 7 PONCE DE LEON BLVD STE 223 Doomlawoffice@ferdleandlones.com CORAL GABLES,FL 33134 Bkx 2679 PON 1738 lammffice@f9rdleandlones-com MONROE COUNTY OFFICIAL RECORDS ,?APX 12-001417112-001417-11CASTANEDA10DIJan 31,20141 MEMORANDUM DATE: August 4, 2014 TO: Lisa A. Granger, Esq. FROM: Nicholas W. Mulick, Esq. RE: Request to Release Code Enforcement Lien 108 Old Fashion Road, Tavernier, Florida ("subject property") ------------ Per our telephone conversation, I have discussed with my clients, Dr. Harley and Robin Stock ("the Stocks"), the requirement that they execute a document, suitable to you, acknowledging as the new owners of the subject property, that short-term rental of the subject property is prohibited by Monroe County ordinance and affirming that they will not use the property for that purpose. I have also communicated with the property owner,Juan Carlos Castaneda,who has authorized me to represent to the County Commission that he consents to the request to release the Code Enforcement lien on 108 Old Fashion Road, Tavernier, Florida, for the purpose of facilitating the sale of the subject property to my clients, pursuant to the terms of the Contract for Sale and Purchase dated as of July 1, 2014, a copy of which I previously transmitted to you. Mr. Castaneda also acknowledges that, by agreeing to release the subject property from the Code Enforcement lien,the Monroe County Board of County Commissioners is not releasing him from his obligation to pay all fines that have accrued, pursuant to the Order imposing fines entered on September 27, 2012 in Case No. CE12070048. Both the Stocks and Mr. Castaneda acknowledge and agree that, if approved by the County Commission, the payment of the sum of$30,000.00 in exchange for the Release of Lien must be paid from the closing proceeds of the sale of the subject property as reflected on the HUD Closing Statement executed in connection with the closing of title and that the original Release of Lien will be held in escrow and not released to the closing agent until you have confirmed receipt of a copy of the executed Warranty Deed, HUD Closing Statement,and a written agreement by my clients that they will not use the subject property for short-term rentals. Please let me know whether I have accurately set forth the terms of our discussion. AS W Reskental Contraiai For Sa�e At�I-Purcnas,e 'Ip 6'RES lRm- EN Sim M WE 1AA '7,00- ACC ERry Q c smm"w "—CC' d!7 D 7 74 7 2 -77-, ............................ ism, W=f eel. vy -"o 00W M" 77� CUE CK c N WI{• "jowwwr WS Not �v Its., onv7p �21 1 1-LART '�N 7 vnpwwvm� Twyn jug van P171, 7 IninkKa, m ME FOR WCEPTANCF OF or .7_ i ny Lv- 1�y w or or -VOYV nw, " 'MEN 24 =5 `7 a., 40777U ;"WR A A,: 77: o� 7:0�1 woo Meng 7r: "J 777,,7 ....... ,mNV'�aWvwxnn n' 5= 00how 0 sny"; -0 Wtoh jawmwMa -1 1 Apy Olson; 7wo wr vom 2nn-nx omwat nq 3,5,4 '49"Cm 35 01"Fou ynw�uny NS 07-07� 71 ]F Wn VMS "y A WMPs -4 Y,vY n 7W Acwb� OF AWW"", mwn& jq,a-V hqui aw SN5 0rwml no Zoo vian AM so vev cec 10=1 0 000 0 7, r�Vnq y WE LOW Cmz"7 Mello . 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