Conlon v. U.S. Bank, N.A. et al

MOTION for summary judgment as to count II of Plaintiff's Amended Complaint

M.D. Fla.March 6, 2017

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION EDWARD PAUL CONLON, Plaintiff, v. U.S. BANK, N.A. and FIVE BROTHERS MORTGAGE COMPANY SERVICES AND SECURING, INC., Defendants. ____________________________________/ Case No. 3:16-cv-379 J20 JBT FIVE BROTHERS MORTGAGE COMPANY SERVICES AND SECURING, INC., Defendant, Third Party Plaintiff, v. CAMERON SECURING & LAWN CARE, LLC, and DANNON D. SMITH, Third Party Defendants. ____________________________________/ FIVE BROTHERS MORTGAGE COMPANY SERVICES AND SECURING, INC.’S MOTION FOR SUMMARY JUDGMENT AS TO COUNT II1 OF PLAINTIFF’S AMENDED COMPLAINT AND INCORPORATED MEMORANDUM OF LAW COMES NOW the Defendant, FIVE BROTHERS MORTGAGE COMPANY SERVICES AND SECURING, INC. (hereinafter “5 BROTHERS”), by and through its undersigned counsel and pursuant to Federal Rule of Civil Procedure 56, hereby moves for a summary judgment in its 1 Plaintiff’s Amended Complaint mislabels Count III against 5 BROTHERS as Count II. Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 1 of 6 PageID 273 Case No. 3:16-cv-379 J20 JBT Page 2 of 6 favor as to Count II of Plaintiff, EDWARD PAUL CONLON’s (hereinafter “Plaintiff”) Amended Complaint and in support thereof states as follows: I. INTRODUCTION This case arises from actions that allegedly occurred at Plaintiff’s property at 120 Crooked Tree Trail, St. Augustine, Florida 32086 (the “Property”). In 2009 Defendant, U.S. BANK, N.A. (hereinafter “U.S. BANK”) filed a Complaint to foreclose on the Property. After the filing of the foreclosure action, U.S. BANK hired various parties to maintain the Property, one of which was 5 BROTHERS. U.S. Bank issued various work orders to 5 BROTHERS to perform work at the property such as lawn mowing, removing trees and vines, debris removal, and providing keys and lockboxes. Through a series of subcontracts, the work orders issued to 5 BROTHERS for the Property were performed by DANNON D. SMITH. Count II of Plaintiff’s Amended Complaint alleges that 5 BROTHERS violated the Florida Consumer Collection Practices Act, Section 559.72, Florida Statutes, by unlawfully seizing and taking possession of the contents of Plaintiff’s home in an attempt to collect a debt owed by Plaintiff to U.S. Bank. Summary Judgment as to Count II is warranted because 5 BROTHERS was not involved with the collection of a consumer debt, a prerequisite to liability under the Florida Consumer Collection Practices Act. II. EVIDENCE RELIED UPON 1. Plaintiff’s Amended Complaint (Doc. 2) 2. Affidavit of Rebecca Sutton (Sutton Aff.) 3. Invoice for Work Order #1797652 attached as Exhibit “A” to Rebecca Sutton Affidavit. Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 2 of 6 PageID 274 Case No. 3:16-cv-379 J20 JBT Page 3 of 6 III.UNDIPSUTED MATERIAL FACTS 1. On February 14, 2014 5 BROTHERS, through its independent contractor, performed an exterior inspection of the Property at the direction of U.S. Bank. (Sutton Aff. ¶ 4). The Property was reported as vacant by the contractor. (Sutton Aff. ¶ 4). 2. After February 14, 2014 U.S. BANK, in light of the vacancy status of the Property, continued to issue work orders to 5 BROTHERS to perform preservation tasks such as installing lockboxes, treating mold, capping dryer vents, capping refrigerator lines, removing interior and exterior debris, removing vines, trimming shrubs, cutting the lawn, securing the pool, cleaning gutters, and tarping the roof. (Sutton Aff. ¶ 5) 3. 5 BROTHERS does not engage in the business of collecting consumer debts and no portion of 5 BROTHERS’ work at the Property involved the collection of debts in any manner. (Sutton Aff. ¶ 6) 4. 5 BROTHERS did not financially benefit from any sale or transfer of the contents of Plaintiff’s house. (Sutton Aff. ¶ 7) 5. 5 BROTHERS did not receive any money from the sale or distribution of Plaintiff’s personal contents at the Property. (Sutton Aff. ¶ 8) 6. 5 BROTHERS did not remit any payments to U.S. BANK. (Sutton Aff. ¶ 9) IV. MEMORANDUM OF LAW AND ARGUMENT a. Standard of Review Summary judgment is proper when if the movant shows there is no genuine dispute as to any material fact and that the movant is entitled to a judgment as a matter of law. Fed.R.Civ.P. 56(a). The purpose of summary judgment is to dispose of unsupported claims or defenses which, Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 3 of 6 PageID 275 Case No. 3:16-cv-379 J20 JBT Page 4 of 6 as a matter of law, do not raise issues of material fact suitable for trial. Celotex Corp. v. Catrett, 477 U.S. 317, 322-23, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). b. Argument - 5 BROTHERS cannot be liable for violating 559.72, Florida Statutes because it is undisputed that 5 BROTHERS was not collecting a consumer debt, a prerequisite to liability under the Florida Consumer Collection Practices Act. Section 559.72, Florida Statutes, begins with the following language, “In collecting consumer debts, no person shall: …” In an attempt to avoid dismissal of the action at the motion to dismiss stage, the Plaintiff asserted in Count II that 5 BROTHERS’ activities at the Property were conducted in an attempt to collect a debt owed by Plaintiff to U.S. BANK. (Doc. 2 ¶ 69) However, it is undisputed that 5 BROTHERS, in performing its work orders at the Property, was not attempting to collect a debt owed to U.S. BANK. See Sutton Aff. ¶ 6-9. 5 BROTHERS is engaged in the business of property preservation. See Sutton Aff. ¶ 3. Its scope of work includes, among other things, lawn maintenance, securing the property with locks, removing interior and exterior debris, and repairing damage to residences. See Sutton Aff. ¶ 5. 5 BROTHERS does not engage in the business of collecting debts. See Sutton Aff. ¶ 6. Beginning in 2014 U.S. BANK began issuing Work Orders to 5 BROTHERS to perform various tasks at the Property. See Sutton Aff. ¶ 4. On February 25, 2014 U.S. BANK issued Work Order #1797652 to 5 BROTHERS to perform work at the Property. See Exhibit “A” to Sutton Aff. As part of the Work Order, 5 BROTHERS was directed to remove 4 cubic yards of interior debris including the broken glass. See Exhibit “A” to Sutton Aff. Plaintiff contends that various items removed from his home were in fact personal belongings and not debris. Regardless of Plaintiff’s contention that the items were personal property and not debris, which is not at issue in this Summary Judgment, it is undisputed that 5 BROTHERS was not operating to collect a consumer debt. 5 BROTHERS did not sell any of Plaintiff’s items, 5 BROTHERS Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 4 of 6 PageID 276 Case No. 3:16-cv-379 J20 JBT Page 5 of 6 did not receive a financial benefit from the sale of any of Plaintiff’s items, and 5 BROTHERS did not remit any monies to U.S. BANK to satisfy the debt owed by the Plaintiff. See Sutton Aff. ¶ 6-9. Summary Judgment as to Count II for Florida Consumer Collection Practices Act (FCCPA) Violations is warranted because 5 BROTHERS was not collecting a consumer debt, a requirement for liability under the FCCPA. V. Prayer for fees pursuant to 559.77, Florida Statutes Section 559.77(2), Florida Statutes provides that “If the court finds that the suit fails to raise a justiciable issue of law or fact, the plaintiff is liable for court costs and reasonable attorney's fees incurred by the defendant.” The facts and law are clear, and have been clear from the inception of the case. 5 BROTHERS is not a debt collector and is not engaged in the collection of consumer debts. As there is no justiciable issue of law or fact, Plaintiff is liable for court costs and attorney’s fees incurred by 5 BROTHERS. WHEREFORE, 5 BROTHERS respectfully requests that this Honorable Court enter an Order granting Summary Judgment in its favor as to Count II (FCCPA Violations) of Plaintiff’s Amended Complaint, awarding 5 BROTHERS its fees and costs pursuant to Section 559.77(2), Florida Statutes, and granting 5 BROTHERS any further relief that this Court deems just and proper. WRIGHT, FULFORD, MOORHEAD & BROWN, P.A. /s/ Nicholas S. Moulos CURTIS L. BROWN, ESQUIRE Florida Bar Number: 856312 cbrown@wfmblaw.com khartin@wfmblaw.com NICHOLAS S. MOULOS, ESQ. Florida Bar No.: 117852 Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 5 of 6 PageID 277 Case No. 3:16-cv-379 J20 JBT Page 6 of 6 nmoulos@wfmblaw.com 505 Maitland Avenue, Suite 1000 Altamonte Springs, Florida 32701 Telephone: 407-425-0234 Attorneys for Defendant Five Brothers CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 6th day of March, 2017, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF System, through which an electronic copy of the foregoing will be sent to those parties on the Service List. Max Story, Esquire, MAX HUNTER STORY, P.A., 328 2nd Avenue North, Jacksonville Beach, Florida 32250, max@storylawgroup.com Albert T. Franson, Esquire, FRANSON, ISELEY & RENDZIO, P.A., 1400 Prudential Drive, Suite 5, Jacksonville, Florida 32207, afranson@fi-law.com, atanner@fi-law.com J. Kirby McDonough, Esquire and S. Douglas Knox, Esquire, QUARLES & BRADY LLP, 101 E. Kennedy Blvd., Suite 3400, Tampa, Florida 33602, Douglas.knox@quarles.com, kirby.mcdonough@quarles.com /s/ Nicholas S. Moulos Nicholas S. Moulos Case 3:16-cv-00379-HES-JBT Document 33 Filed 03/06/17 Page 6 of 6 PageID 278 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 1 of 27 PageID 279 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 2 of 27 PageID 280 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 3 of 27 PageID 281 EXHIBIT “A” Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 4 of 27 PageID 282 Five Brothers Mortgage Company Services & Securing, Inc. 12220 E. 13 Mile Road, Suite 100 Warren, MI 48093 Tel: 586-772-7600 Fax: 586-772-3660 Bill To: US Bank Home Mortgage FORECLOSURE 800 MORELAND STREET OWENSBORO, KY 42301 INVOICE # P1797652 Regarding Mortgagor: EDWARD P CONLON Address: 120 CROOKED TREE TRL SAINT AUGUSTINE, FL 32086 FHA Case: 292069243 Date Ordered: 2/25/2014 Date Completed: 2/28/2014 Date Invoiced: 3/5/2014 Type of Housing: SINGLE FAMILY Loan Number Contact Department Loan Type 8400040490 McNealK FORECLOSURE FHLM Description Size United Inches Qty Price Units Amount CAPPED DRYER VENT; PER WO INSTRUCTION LOC:INTERIOR 1 50 EA $50.00 CAPPED 1/4" REFRIGERATOR LINE ; PER WO INSTRUCTION LOC:INTERIOR 1 50 EA $50.00 BLEACH TREATED 6'X3' AREA OF MOLD USING 50/50 BLEACH/WATER SOLUTION; MOISTURE ; REQUIRES: 1 MEN X 1 HOURS LOC:IN GARAGE BEHIND WATER SOFTENER 18 0.75 SF $13.50 REMOVED EXTERIOR DEBRIS CONSISTING OF BROKEN WINDOWS, ROTTEN SAWHORSES, WOOD, ETC.; PER WO INSTRUCTIONS LOC:EXTERIOR 2 40 CYD $80.00 FB003946 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 5 of 27 PageID 283 REMOVED INTERIOR DEBRIS CONSISTING OF PLASTIC, PAPER,BROKEN FURNITURE, EMPTY BOTTLESAND CONTAINERS, HANGERS, AND GLASS FROM BROKEN WINDOW; PER WO INSTRUCTION LOC:INTERIOR 4 40 CYD $160.00 Total Amount: $353.50 Notes: COMPLETED WORK ORDER PROPERTY IS VACANT AND SECURE PREVIOUS BIDS PENDING FOR DAMAGES, SAFETY HAZARDS, YARD MAINTENANCE FB003947 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 6 of 27 PageID 284 PROPERTY MAINTENANCE RESULTS Company:LMM Attention:McNealK Address:EDWARD P CONLON 120 CROOKED TREE TRL SAINT AUGUSTINE, FL 32086 Dept:FORECLOSURE Loan Number:8400040490 Loan Type:FHL WO#:1797652 Date Work Ordered: 2/25/2014 Date Work Started: 2/28/2014 Date Work Completed: 2/28/2014 Entry Lock Code: ;67767 OCN What Ordered:WORK ORDER What Completed: WORK ORDER Padlock Code: Description Unit 1# Unit 2# Unit 3# Unit 4# Occupancy VACANT Ist Time Vacant Date 2/14/2014 Secure Date 2/21/2014 Winterization Date Comments:COMPLETED WORK ORDER PROPERTY IS VACANT AND SECURE PREVIOUS BIDS PENDING FOR DAMAGES, SAFETY HAZARDS, YARD MAINTENANCE Completed Size/UI Quantity CAPPED DRYER VENT; PER WO INSTRUCTION LOC:INTERIOR 1 EA CAPPED 1/4" REFRIGERATOR LINE ; PER WO INSTRUCTION LOC:INTERIOR 1 EA FB003948 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 7 of 27 PageID 285 BLEACH TREATED 6'X3' AREA OF MOLD USING 50/50 BLEACH/WATER SOLUTION; MOISTURE ; REQUIRES: 1 MEN X 1 HOURS LOC:IN GARAGE BEHIND WATER SOFTENER 18 SF REMOVED EXTERIOR DEBRIS CONSISTING OF BROKEN WINDOWS, ROTTEN SAWHORSES, WOOD, ETC.; PER WO INSTRUCTIONS LOC:EXTERIOR 2 CYD REMOVED INTERIOR DEBRIS CONSISTING OF PLASTIC, PAPER,BROKEN FURNITURE, EMPTY BOTTLESAND CONTAINERS, HANGERS, AND GLASS FROM BROKEN WINDOW; PER WO INSTRUCTION LOC:INTERIOR 4 CYD FB003949 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 8 of 27 PageID 286 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 closet 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 crew's truck 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 street sign 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 unfinished bathroom FB003950 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 9 of 27 PageID 287 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 address number 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bathroom 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bathroom 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (aft) FB003951 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 10 of 27 PageID 288 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (bef) FB003952 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 11 of 27 PageID 289 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 bleach treated 6'x3' area of mold using 50/5 (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped 1/4" refrigerator line ; per wo instr (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped 1/4" refrigerator line ; per wo instr (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped 1/4" refrigerator line ; per wo instr (bef) FB003953 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 12 of 27 PageID 290 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped dryer vent; per wo instruction (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped dryer vent; per wo instruction (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 capped dryer vent; per wo instruction (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 closet FB003954 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 13 of 27 PageID 291 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 crew truck 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 front door 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 front view 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (aft) FB003955 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 14 of 27 PageID 292 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (bef) FB003956 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 15 of 27 PageID 293 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed exterior debris consisting of broken (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003957 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 16 of 27 PageID 294 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003958 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 17 of 27 PageID 295 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003959 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 18 of 27 PageID 296 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003960 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 19 of 27 PageID 297 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003961 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 20 of 27 PageID 298 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) FB003962 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 21 of 27 PageID 299 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (aft) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) FB003963 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 22 of 27 PageID 300 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) FB003964 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 23 of 27 PageID 301 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) FB003965 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 24 of 27 PageID 302 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) FB003966 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 25 of 27 PageID 303 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) FB003967 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 26 of 27 PageID 304 Account #: 8400040490 Order #: 1797652 Address: 120 CROOKED TREE TRL SAINT AUGUSTINE FL 32086 Case #: 292069243 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plasti (bef) 02/28/2014 12:00:00 PM Date Completed: 02/28/2014 removed interior debris consisting of plastic, pap FB003968 Case 3:16-cv-00379-HES-JBT Document 33-1 Filed 03/06/17 Page 27 of 27 PageID 305