Empathy List Archives

HH

Harry Heist

Mon, Jan 12, 2015 9:19 PM

Many of you who know me will fall off their chair but I am trying to assist
a friend who is fighting an eviction.

 Fictitious name owner does not match the case style at all.

 The process server lied about when it was served

 Eventually one of the occupants will file a Third Party Affidavit as

she was not served but that comes later.

 Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is
going to file pro se (tomorrow is her deadline) but I told her it should
look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: http://www.evict.com/ www.evict.com
Email: mailto:harry@evict.com harry@evict.com

https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND
INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR
DISTRIBUTION IS STRICTLY PROHIBITED.

Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: <http://www.evict.com/> www.evict.com Email: <mailto:harry@evict.com> harry@evict.com <https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

ML

Martin Lawyer

Mon, Jan 12, 2015 11:30 PM

The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner.

                  Marty

                 C. Martin (Marty) Lawyer, III
                 Florida Bar # 128095
                 Bay Area Legal Services, Inc.
                 1302  N. 19th St.,  Suite # 400
                 Tampa,  FL 33605-5230
                 (813)  232-1222, Ext.109
                  FAX:  248-9922

"Preserving Independence, Hope and Dignity"

From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, 12 January, 2015 16:20
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: www.evict.com http://www.evict.com/
Email: harry@evict.com mailto:harry@evict.com
[cid:image001.png@01D02E95.D5B50700]https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner. Marty C. Martin (Marty) Lawyer, III Florida Bar # 128095 Bay Area Legal Services, Inc. 1302 N. 19th St., Suite # 400 Tampa, FL 33605-5230 (813) 232-1222, Ext.109 FAX: 248-9922 "Preserving Independence, Hope and Dignity" From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, 12 January, 2015 16:20 To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: www.evict.com<http://www.evict.com/> Email: harry@evict.com<mailto:harry@evict.com> [cid:image001.png@01D02E95.D5B50700]<https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

LC

Leonard Cabral

Tue, Jan 13, 2015 12:00 AM

This should help you out Harry. Standing and Fictitious Name are included. Some of this does not apply due to the 2013 changes to the statutes.

Leonard P. Cabral, Esq.
Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, January 12, 2015 4:20 PM
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: www.evict.com http://www.evict.com/
Email: harry@evict.com mailto:harry@evict.com
[cid:image001.png@01D02E9A.14B916E0]https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

This should help you out Harry. Standing and Fictitious Name are included. Some of this does not apply due to the 2013 changes to the statutes. Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, January 12, 2015 4:20 PM To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: www.evict.com<http://www.evict.com/> Email: harry@evict.com<mailto:harry@evict.com> [cid:image001.png@01D02E9A.14B916E0]<https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

LC

Leonard Cabral

Tue, Jan 13, 2015 12:08 AM

Marty:
I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign)
Leonard P. Cabral, Esq.
Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer
Sent: Monday, January 12, 2015 6:31 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner.

                  Marty

                 C. Martin (Marty) Lawyer, III
                 Florida Bar # 128095
                 Bay Area Legal Services, Inc.
                 1302  N. 19th St.,  Suite # 400
                 Tampa,  FL 33605-5230
                 (813)  232-1222, Ext.109
                  FAX:  248-9922

"Preserving Independence, Hope and Dignity"

From: landten-bounces@lists.flabarrpptl.org mailto:landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, 12 January, 2015 16:20
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: www.evict.com http://www.evict.com/
Email: harry@evict.com mailto:harry@evict.com
[cid:image001.png@01D02E9B.2C2E8840]https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

Marty: I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign) Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer Sent: Monday, January 12, 2015 6:31 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner. Marty C. Martin (Marty) Lawyer, III Florida Bar # 128095 Bay Area Legal Services, Inc. 1302 N. 19th St., Suite # 400 Tampa, FL 33605-5230 (813) 232-1222, Ext.109 FAX: 248-9922 "Preserving Independence, Hope and Dignity" From: landten-bounces@lists.flabarrpptl.org<mailto:landten-bounces@lists.flabarrpptl.org> [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, 12 January, 2015 16:20 To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: www.evict.com<http://www.evict.com/> Email: harry@evict.com<mailto:harry@evict.com> [cid:image001.png@01D02E9B.2C2E8840]<https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

DS

Daniel S. Carusi

Tue, Jan 13, 2015 1:43 AM

Would like some feedback as to 2 following scenarios:

   CT issued to lender  in 2012. Lender conveys to Freddie Mac in

In 2014 Freddie Mac obtains various orders directing clerk to issue
various writs of possession against "tenant" (I state "tenant" only
because that is what the orders state) who had filed a motion to stay a
previously issued writ. Prior to execution of the writ, Feddie Mac conveys
to an investor. Writ has been returned unexecuted. Assume there is no
written lease. I have no other facts regarding "tenants" status.

Do you believe person in possession is a tenant, somehow subject to Ch 83
Part 2, or some other status?

  CT issued  to lender on  a duplex, occupied by previous owner and a

tenant of previous owner. Lender conveys to investor. Previous owner is
removed through a detainer action. Tenant answers separate detainer stating
she is a tenant and produces what purports to be a bona fide written lease
that expires in April, 2015. My quick research shows that Protecting
Tenants at Foreclosure Act sunset on 12-31-14. If this is correct, (1)
does anybody have an opinion as to status of tenant after Act sunsets? And
(2) to remove this tenant who hasn't paid since investor took title, 3 day
notice calculating rent from day investor took title?

Feedback will be appreciated.

DO NOT SEND NOTICES, MOTIONS OR PLEADINGS TO THE SENDER'S E-MAIL ADDRESS.
DOING SO DOES NOT CONSTITUTE LEGAL NOTICE AS REQUIRED BY THE RULES OF COURT.
ALL SUCH NOTICES, PLEADINGS OR MOTIONS MUST BE SENT TO SERVICE
mailto:PLEADINGS@VOVALAW.COM PLEADINGS@CARUSILAW.COM.

Daniel S. Carusi, Esq.

Daniel S. Carusi. P.A.

517 SW 1 Avenue

Ft. Lauderdale, FL 33301

954.527.0101

954.524.4169 F

This message and the documents attached to it, if any, are intended only for
the use of the addressee and may contain information that is PRIVILEGED and
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intended recipient, you are hereby notified that any dissemination of this
communication is strictly prohibited. If you have received this
communication in error, please delete all electronic copies of this message
and its attachments, if any, destroy any hard copies you may have created
and notify me immediately.

Tax Advice Disclosure: To ensure compliance with requirements imposed by the
IRS under Circular 230, we inform you that any U.S. federal tax advice
contained in this communication (including any attachments), unless
otherwise specifically stated, was not intended or written to be used, and
cannot be used, for the purpose of (1) avoiding penalties under the Internal
Revenue Code or (2) promoting, marketing or recommending to another party
any matters addressed herein.

The information contained in this transmission may contain privileged and
confidential information. It is intended only for the use of the person(s)
named above. If you are not the intended recipient, you are hereby notified
that any review, dissemination, distribution or duplication of this
communication is strictly prohibited. If you are not the intended recipient,
please contact the sender by reply email and destroy all copies of the
original message. To reply to our email administrator directly, please send
an email to apolloniaauciello@bellsouth.net.

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral
Sent: Monday, January 12, 2015 7:09 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

Marty:

I fell off my chair, did you? How many others fell off their chair. Do I
smell a McDonalds coffee case brewing. (just kidding about McDonalds, I
don't think the woman received enough money for her injuries. If you watch
the DVD "Hot Coffee" you may agree. Great tort reform campaign)

Leonard P. Cabral, Esq.

Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer
Sent: Monday, January 12, 2015 6:31 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

The attached should get you started. In the Answer, your friend should also
deny that Plaintiff is the owner.

                  Marty



                 C. Martin (Marty) Lawyer, III

                 Florida Bar # 128095

                 Bay Area Legal Services, Inc.

                 1302  N. 19th St.,  Suite # 400

                 Tampa,  FL 33605-5230

                 (813)  232-1222, Ext.109

                  FAX:  248-9922

"Preserving Independence, Hope and Dignity"

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, 12 January, 2015 16:20
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist
a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit

as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is
going to file pro se (tomorrow is her deadline) but I told her it should
look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: http://www.evict.com/ www.evict.com
Email: mailto:harry@evict.com harry@evict.com

https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND
INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR
DISTRIBUTION IS STRICTLY PROHIBITED.

Would like some feedback as to 2 following scenarios: 1. CT issued to lender in 2012. Lender conveys to Freddie Mac in 2013. In 2014 Freddie Mac obtains various orders directing clerk to issue various writs of possession against "tenant" (I state "tenant" only because that is what the orders state) who had filed a motion to stay a previously issued writ. Prior to execution of the writ, Feddie Mac conveys to an investor. Writ has been returned unexecuted. Assume there is no written lease. I have no other facts regarding "tenants" status. Do you believe person in possession is a tenant, somehow subject to Ch 83 Part 2, or some other status? 2. CT issued to lender on a duplex, occupied by previous owner and a tenant of previous owner. Lender conveys to investor. Previous owner is removed through a detainer action. Tenant answers separate detainer stating she is a tenant and produces what purports to be a bona fide written lease that expires in April, 2015. My quick research shows that Protecting Tenants at Foreclosure Act sunset on 12-31-14. If this is correct, (1) does anybody have an opinion as to status of tenant after Act sunsets? And (2) to remove this tenant who hasn't paid since investor took title, 3 day notice calculating rent from day investor took title? Feedback will be appreciated. DO NOT SEND NOTICES, MOTIONS OR PLEADINGS TO THE SENDER'S E-MAIL ADDRESS. DOING SO DOES NOT CONSTITUTE LEGAL NOTICE AS REQUIRED BY THE RULES OF COURT. ALL SUCH NOTICES, PLEADINGS OR MOTIONS MUST BE SENT TO SERVICE <mailto:PLEADINGS@VOVALAW.COM> PLEADINGS@CARUSILAW.COM. Daniel S. Carusi, Esq. Daniel S. Carusi. P.A. 517 SW 1 Avenue Ft. Lauderdale, FL 33301 954.527.0101 954.524.4169 F This message and the documents attached to it, if any, are intended only for the use of the addressee and may contain information that is PRIVILEGED and CONFIDENTIAL, and/or may contain ATTORNEY WORK PRODUCT. If you are not the intended recipient, you are hereby notified that any dissemination of this communication is strictly prohibited. If you have received this communication in error, please delete all electronic copies of this message and its attachments, if any, destroy any hard copies you may have created and notify me immediately. ------------------------------------------------------- Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. The information contained in this transmission may contain privileged and confidential information. It is intended only for the use of the person(s) named above. If you are not the intended recipient, you are hereby notified that any review, dissemination, distribution or duplication of this communication is strictly prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy all copies of the original message. To reply to our email administrator directly, please send an email to apolloniaauciello@bellsouth.net. From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral Sent: Monday, January 12, 2015 7:09 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions Marty: I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign) Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer Sent: Monday, January 12, 2015 6:31 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner. Marty C. Martin (Marty) Lawyer, III Florida Bar # 128095 Bay Area Legal Services, Inc. 1302 N. 19th St., Suite # 400 Tampa, FL 33605-5230 (813) 232-1222, Ext.109 FAX: 248-9922 "Preserving Independence, Hope and Dignity" From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, 12 January, 2015 16:20 To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: <http://www.evict.com/> www.evict.com Email: <mailto:harry@evict.com> harry@evict.com <https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

HH

Harry Heist

Tue, Jan 13, 2015 8:20 PM

Thank you Leonard and Martin.

Harry Heist

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: http://www.evict.com/ www.evict.com
Email: mailto:harry@evict.com harry@evict.com

https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND
INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR
DISTRIBUTION IS STRICTLY PROHIBITED.

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral
Sent: Monday, January 12, 2015 7:09 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

Marty:

I fell off my chair, did you? How many others fell off their chair. Do I
smell a McDonalds coffee case brewing. (just kidding about McDonalds, I
don't think the woman received enough money for her injuries. If you watch
the DVD "Hot Coffee" you may agree. Great tort reform campaign)

Leonard P. Cabral, Esq.

Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer
Sent: Monday, January 12, 2015 6:31 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

The attached should get you started. In the Answer, your friend should also
deny that Plaintiff is the owner.

                  Marty



                 C. Martin (Marty) Lawyer, III

                 Florida Bar # 128095

                 Bay Area Legal Services, Inc.

                 1302  N. 19th St.,  Suite # 400

                 Tampa,  FL 33605-5230

                 (813)  232-1222, Ext.109

                  FAX:  248-9922

"Preserving Independence, Hope and Dignity"

From: landten-bounces@lists.flabarrpptl.org
[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, 12 January, 2015 16:20
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist
a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit

as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is
going to file pro se (tomorrow is her deadline) but I told her it should
look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: http://www.evict.com/ www.evict.com
Email: mailto:harry@evict.com harry@evict.com

https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND
INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR
DISTRIBUTION IS STRICTLY PROHIBITED.

Thank you Leonard and Martin. Harry Heist LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: <http://www.evict.com/> www.evict.com Email: <mailto:harry@evict.com> harry@evict.com <https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED. From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral Sent: Monday, January 12, 2015 7:09 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions Marty: I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign) Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer Sent: Monday, January 12, 2015 6:31 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner. Marty C. Martin (Marty) Lawyer, III Florida Bar # 128095 Bay Area Legal Services, Inc. 1302 N. 19th St., Suite # 400 Tampa, FL 33605-5230 (813) 232-1222, Ext.109 FAX: 248-9922 "Preserving Independence, Hope and Dignity" From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, 12 January, 2015 16:20 To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: <http://www.evict.com/> www.evict.com Email: <mailto:harry@evict.com> harry@evict.com <https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

LC

Leonard Cabral

Wed, Jan 14, 2015 1:36 AM

Just mark it on the "White Castle" I O U :)

Leonard P. Cabral, Esq.
Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Tuesday, January 13, 2015 3:20 PM
To: 'RPPTL Landlord Tenant Committee'
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

Thank you Leonard and Martin.

Harry Heist

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: www.evict.com http://www.evict.com/
Email: harry@evict.com mailto:harry@evict.com
[cid:image001.png@01D02F70.8EF86330]https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

From: landten-bounces@lists.flabarrpptl.org mailto:landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral
Sent: Monday, January 12, 2015 7:09 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

Marty:
I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign)
Leonard P. Cabral, Esq.
Leonardcabral@lenslaw.com mailto:Leonardcabral@lenslaw.com

From: landten-bounces@lists.flabarrpptl.org mailto:landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org]mailto:[mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Martin Lawyer
Sent: Monday, January 12, 2015 6:31 PM
To: RPPTL Landlord Tenant Committee
Subject: Re: [RPPTL LandTen] Eviction Defense Motions

The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner.

                  Marty

                 C. Martin (Marty) Lawyer, III
                 Florida Bar # 128095
                 Bay Area Legal Services, Inc.
                 1302  N. 19th St.,  Suite # 400
                 Tampa,  FL 33605-5230
                 (813)  232-1222, Ext.109
                  FAX:  248-9922

"Preserving Independence, Hope and Dignity"

From: landten-bounces@lists.flabarrpptl.org mailto:landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist
Sent: Monday, 12 January, 2015 16:20
To: 'RPPTL Landlord Tenant Committee'
Subject: [RPPTL LandTen] Eviction Defense Motions

Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction.

  Fictitious name owner does not match the case style at all.

  The process server lied about when it was served

  Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later.

  Rent is way off so she wants to file a Motion to Determine rent

Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case.

Thanks!

Harry

LAW OFFICES OF
HEIST, WEISSE & WOLK P.A.
PH: 1 800 253 8428
FAX: 1 800 367 9038
"Serving the Property Management Professional"
Website: www.evict.com http://www.evict.com/
Email: harry@evict.com mailto:harry@evict.com
[cid:image001.png@01D02F70.8EF86330]https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870

Visit us on Facebook

THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

Just mark it on the "White Castle" I O U :) Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com From: landten-bounces@lists.flabarrpptl.org [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Tuesday, January 13, 2015 3:20 PM To: 'RPPTL Landlord Tenant Committee' Subject: Re: [RPPTL LandTen] Eviction Defense Motions Thank you Leonard and Martin. Harry Heist LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: www.evict.com<http://www.evict.com/> Email: harry@evict.com<mailto:harry@evict.com> [cid:image001.png@01D02F70.8EF86330]<https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED. From: landten-bounces@lists.flabarrpptl.org<mailto:landten-bounces@lists.flabarrpptl.org> [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Leonard Cabral Sent: Monday, January 12, 2015 7:09 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions Marty: I fell off my chair, did you? How many others fell off their chair. Do I smell a McDonalds coffee case brewing. (just kidding about McDonalds, I don't think the woman received enough money for her injuries. If you watch the DVD "Hot Coffee" you may agree. Great tort reform campaign) Leonard P. Cabral, Esq. Leonardcabral@lenslaw.com<mailto:Leonardcabral@lenslaw.com> From: landten-bounces@lists.flabarrpptl.org<mailto:landten-bounces@lists.flabarrpptl.org> [mailto:landten-bounces@lists.flabarrpptl.org]<mailto:[mailto:landten-bounces@lists.flabarrpptl.org]> On Behalf Of Martin Lawyer Sent: Monday, January 12, 2015 6:31 PM To: RPPTL Landlord Tenant Committee Subject: Re: [RPPTL LandTen] Eviction Defense Motions The attached should get you started. In the Answer, your friend should also deny that Plaintiff is the owner. Marty C. Martin (Marty) Lawyer, III Florida Bar # 128095 Bay Area Legal Services, Inc. 1302 N. 19th St., Suite # 400 Tampa, FL 33605-5230 (813) 232-1222, Ext.109 FAX: 248-9922 "Preserving Independence, Hope and Dignity" From: landten-bounces@lists.flabarrpptl.org<mailto:landten-bounces@lists.flabarrpptl.org> [mailto:landten-bounces@lists.flabarrpptl.org] On Behalf Of Harry Heist Sent: Monday, 12 January, 2015 16:20 To: 'RPPTL Landlord Tenant Committee' Subject: [RPPTL LandTen] Eviction Defense Motions Many of you who know me will fall off their chair but I am trying to assist a friend who is fighting an eviction. 1. Fictitious name owner does not match the case style at all. 2. The process server lied about when it was served 3. Eventually one of the occupants will file a Third Party Affidavit as she was not served but that comes later. 4. Rent is way off so she wants to file a Motion to Determine rent Can any of my tenant helping buddies send me some sample pleadings? She is going to file pro se (tomorrow is her deadline) but I told her it should look good. No one in this listserve is the attorney who filed the case. Thanks! Harry LAW OFFICES OF HEIST, WEISSE & WOLK P.A. PH: 1 800 253 8428 FAX: 1 800 367 9038 "Serving the Property Management Professional" Website: www.evict.com<http://www.evict.com/> Email: harry@evict.com<mailto:harry@evict.com> [cid:image001.png@01D02F70.8EF86330]<https://www.facebook.com/pages/Heist-Weisse-Wolk-PA/343965575625870> Visit us on Facebook THIS E-MAIL MESSAGE IS CONFIDENTIAL, ATTORNEY-CLIENT PRIVILEGED, AND INTENDED FOR THE PERSONS NAMED ABOVE ONLY. ALL OTHER USE, COPYING, OR DISTRIBUTION IS STRICTLY PROHIBITED.

landten@lists.flabarrpptl.org

[RPPTL LandTen] Eviction Defense Motions