Filing # 36473683 E-Filed 01/12/2016 04:13:03 PM

THIS IS NOT A COMMERCIAL FORCLOSURE

IN THE CIRCUIT COURT OF THE

FIFTH JUDICIAL CIRCUIT FLORIDA
IN AND FOR MARION COUNTY

REVERSE MORTGAGE SOLUTIONS, INC.,

Plaintiff,
vs.

CASE NO.: 2013-CA-000115

42-2013-CA-000115-AXXX-XX
Residential HECM Foreclosure Case
Florida Homestead of Neil J. Gillespie

NEIL J. GILLESPIE AND MARK GILLESPIE

AS CO-TRUSTEES OF THE GILLESPIE
FAMILY LIVING TRUST AGREEMENT
DATED FEBRUARY 10, 1997, ET AL.
Defendants.
________________________________________/
DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT
F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)
Defendant Neil J. Gillespie, individually, and as former Trustee (F.S. Ch. 736 Part III) of
the terminated Gillespie Family Living Trust Agreement Dated February 10, 1997 (Terminated
Trust), an indigent non-lawyer, unable to obtain adequate counsel, a consumer of legal and court
services affecting interstate commerce, a consumer of personal, family and household goods and
services, consumer transactions in interstate commerce, a person with disabilities, and a vulnerable
adult, henceforth in the first person, reluctantly appears pro se, and files this verified motion to
strike Plaintiffs Motion to Default under F.S. ch. 702, 702.015, Florida Rules of Civil Procedure
Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a), and states:
1.

I move to strike the Plaintiffs Motion to Default, and Default, under Rule 1.140(f):
RULE 1.140. DEFENSES
(f) Motion to Strike. A party may move to strike or the court may strike redundant,
immaterial, impertinent, or scandalous matter from any pleading at any time.

2.

I move to strike the Plaintiffs Motion to Default, and Default, under Rule 1.150(a):
RULE 1.150. SHAM PLEADINGS

DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT

F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)

January 12, 2016

(a) Motion to Strike. If a party deems any pleading or part thereof filed by another party
to be a sham, that party may move to strike the pleading or part thereof before the cause
is set for trial and the court shall hear the motion, taking evidence of the respective
parties, and if the motion is sustained, the pleading to which the motion is directed shall
be stricken. Default and summary judgment on the merits may be entered in the
discretion of the court or the court may permit additional pleadings to be filed for good
cause shown.
(b) Contents of Motion. The motion to strike shall be verified and shall set forth fully
the facts on which the movant relies and may be supported by affidavit. No traverse of
the motion shall be required.
3.

Plaintiffs Motion to Default, Filing # 36269740 E-Filed 01/07/2016 12:55:31 PM, shows a

wrong filing date of January 7, 2015 (Exhibit 1).

Plaintiffs Motion to Default-Default Entered (not entered), Filing # 36269740 E-Filed
01/07/2016 12:55:31 PM, shows a wrong filing date of January 7, 2015 (Exhibit 2).
I demand strict compliance with all legal process used by the Plaintiff to foreclose my
Florida residential homestead property.
4.

On January 8, 2016 I filed 4 responses to the Plaintiffs Notice of Action to Foreclose:

A.
Plaintiffs Notice of Action to Foreclose the UNKNOWN SETTLORS
BENEFICIARIES OF THE GILLESPIE FAMILY LIVING TRUST AGREEMENT
DATED FEBRUARY 10, 1997.

Filing # 36307811 E-Filed 01/08/2016 09:22:08 AM

B.
Plaintiffs Notice of Action to Foreclose the UNKNOWN SETTLORS
BENEFICIARIES OF THE GILLESPIE FAMILY LIVING TRUST AGREEMENT
DATED FEBRUARY 10, 1997, 8092 SW 115TH LOOP, OCALA, FL 34481.

Filing # 36314514 E-Filed 01/08/2016 10:40:40 AM

C.
Plaintiffs Notice of Action to Foreclose the UNKNOWN SPOUSE OF
ELIZABETH BAUERLE

Filing # 36309703 E-Filed 01/08/2016 09:47:53 AM

D.
Plaintiffs Notice of Action to Foreclose the UNKNOWN SPOUSE OF
ELIZABETH BAUERLE, 6356 SW 106th Place, Ocala, Florida, 34476.

Filing # 36311213 E-Filed 01/08/2016 10:05:16 AM

DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT

F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)

5.

January 12, 2016

The Plaintiff filed an improper Motion for Default given I filed DEFENDANTS

MOTION TO EXTEND TIME TO RESPOND to and including January 7, 2016, Filing #

35941683 E-Filed 12/28/2015 03:45:12 PM. Plaintiffs motion is wrongly dated January 7, 2015.
6.

I notified the Court January 11, 2016 additional time was required for verification of

marriage records for the unknown spouse of Elizabeth Bauerle, n.k.a. Elizabeth Bidgood, see
NOTICE OF FILING BY DEFENDANT NEIL J. GILLESPIE Verification of Marriage
Records, Filing # 36416149 E-Filed 01/11/2016 05:11:25 PM.
7.

The Plaintiff knowingly and wrongly filed this action as a commercial foreclosure on

its civil cover sheet (Exhibit 3) violation of Rule 1.100(c)(2) Pleadings and Motions, when in
fact the Plaintiff and its counsel knows this is a residential foreclosure of my Florida homestead.
8.

On February 7, 2015, I filed my affidavit of residential homestead,

AFFIDAVIT OF NEIL J. GILLESPIE OF RESIDENTIAL HOMESTEAD
THIS IS NOT A COMMERCIAL FORCLOSURE
Filing # 23497600 E-Filed 02/07/2015 11:56:00 PM

9.

I notified Gregory C. Harrell, General Counsel to David R. Ellspermann, Marion County

Clerk of Court & Comptroller by letter December 24, 2014 (Exhibit 4) of the Clerks duty and
the civil cover sheet (form 1.997), Rule 1.100(c)(2), in part:
Mr. Harrell, under Rule 1.100(c)(2) ...all proceedings in the action shall be abated until
a properly executed cover sheet is completed and filed.... This is the Clerks duty, see
Rule 1.100(c)(2) Pleadings and Motions.
(2) A civil cover sheet (form 1.997) shall be completed and filed with the clerk at the
time an initial complaint or petition is filed by the party initiating the action. If the cover
sheet is not filed, the clerk shall accept the complaint or petition for filing; but all
proceedings in the action shall be abated until a properly executed cover sheet is
completed and filed. The clerk shall complete the civil cover sheet for a party appearing
pro se.

DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT

F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)

January 12, 2016

Currently the civil cover sheet (form 1.997) is not properly executed as completed and
filed. The Clerk has a ministerial duty under Rule 1.100(c)(2), ...all proceedings in the
action shall be abated until a properly executed cover sheet is completed and filed..
As of today Clerk David R. Ellspermann has not abated the proceedings until a properly
executed cover sheet is completed and filed. Rule 1.100(c)(2).
10.

The Plaintiff has failed to comply with Florida Statutes Chapter 702, Foreclosure of

Mortgages and Statutory Liens, and section 702.015 Elements of complaint; lost, destroyed, or
stolen note affidavit. The Plaintiff, inter alia, has not filed the original note with the Clerk.
11.

The Plaintiff has failed to comply with Florida Rules of Civil Procedure, Rule 1.115,

Pleading Mortgage Foreclosures and subparts (a) through (e). The Plaintiff, inter alia, has not
filed the original note with the Clerk.
WHEREFORE, I move the Court to dismiss with prejudice Plaintiffs entire action. In the
alternative, I move the Court to strike the Plaintiffs Motion to Default, and Default.
VERIFICATION OF NEIL J. GILLESPIE
Under penalty of perjury, I declare that I have read the foregoing, and the facts alleged
therein are true and correct to the best of my knowledge and belief.
RESPECTFULLY SUBMITTED January 12, 2016.

Neil J. Gillespie, individually, and former Trustee,

F.S. Ch. 736 Part III, of the Terminated Trust
8092 SW 115th Loop
Ocala, Florida 34481
Phone: 352-854-7807
Email: neilgillespie@mfi.net

DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT

F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)

January 12, 2016

Service List January 12, 2016

I hereby certify the following names were served by email today January 12, 2016
through the Florida Portal.

Neil J. Gillespie
Mr. Curtis Wilson, Esq.
McCalla Raymer, LLC
225 E. Robinson Street, Ste. 660
Orlando, FL 32801
Email: MRService@mccallaraymer.com

Ms. Colleen Murphy Davis, AUSA

400 N. Tampa Street, Suite 3200
Tampa, FL 33602
Email: USAFLM.HUD@usdoj.gov
JAXSFFORECLOSURES@hud.gov

Gregory C. Harrell
General Counsel to David R. Ellspermann,
Marion County Clerk of Court & Comptroller
P.O. Box 1030
Ocala, Florida 34478-1030
Email: gharrell@marioncountyclerk.org

David R. Ellspermann Marion County Clerk

of Court & Comptroller
P.O. Box 1030
Ocala, Florida 34478-1030
Email: Ellspermann@marioncountyclerk.org

Development & Construction Corporation

of America, c/o Carol Olson, Vice President
of Administration and Secretary-Treasurer,
for RA Priya Ghumman
10983 SW 89 Avenue
Ocala, FL 34481
Email: colson@deccahomes.com

Oak Run Homeowners Association, Inc.

c/o Board of Directors, orhaboard@yahoo.com

Neil J. Gillespie and Mark Gillespie as Co-Trustees of the Gillespie Family Living Trust
Agreement dated February 10, 1997
8092 SW 115th Loop
Ocala, FL 34481
Email: neilgillespie@mfi.net
Email: mark.gillespie@att.net
Neil J. Gillespie
8092 SW 115th Loop
Ocala, FL 34481
Email: neilgillespie@mfi.net

Mark Gillespie
7504 Summer Meadows Drive
Ft. Worth, TX 76123
Email: mark.gillespie@att.net

Unknown spouse of Mark Gillespie n/k/a Joetta Gillespie

7504 Summer Meadows Drive
5

DEFENDANTS VERIFIED MOTION TO STIKE PLAINTIFFS MOTION TO DEFAULT

F.S. ch. 702, 702.015, Rule 1.100(c)(2), Rule 1.115(a)-(e), Rule 1.140(f), Rule 1.150(a)

January 12, 2016

Ft. Worth, TX 76123

Email: mark.gillespie@att.net
Unknown Settlors/Beneficiaries of The Gillespie Family Living Trust Agreement dated
February 10, 1997
8092 SW 115th Loop
Ocala, FL 34481
Email: neilgillespie@mfi.net
Elizabeth Bauerle n/k/a Elizabeth Bidwood
7504 Summer Meadow Drive
Ft. Worth, TX 76123
Email: mark.gillespie@att.net

Unknown spouse of Elizabeth Bauerle

6356 SW 106th Place
Ocala, FL 34476
Email: neilgillespie@mfi.net

Filing # 36473683
36269740 E-Filed 01/12/2016
01/07/2016 04:13:03
12:55:31 PM

Filing # 36473683 E-Filed 01/12/2016 04:13:03 PM

Filing # 36473683 E-Filed 01/12/2016 04:13:03 PM

Form 1.997 CIVIL COVER SHEET

The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other
papers as required by law. This form sh~lI~be.fi~d by the plaintiff or petitioner for the use of the Clerk of the Court for the purpose of
reporting judicial workload data pursuanit<Y Ftbrlda Statutes Section 25.075.
CASE STYLE

I.

IN THE CIRCUIT COURT OF THE FIFTH

JUDICIAL CIRCUIT OF FLORIDA IN AND
FOR MARION COUNTY
Plaintiff

Case #
Judge:

REVERSE MORTGAGE SOLUTIONS, INC.

l 3. - \ \ :- L.ea=

vs.
Defendant

II.

NEIL J. GILLESPIE AND MARK GILLESPIE AS CO-TRUSTEES

OF THE GILLESPIE FAMILY LIVING TRUST AGREEMENT
DATED FEBRUARY 10, 1997, et ale
.~ '~"

TYPE OF CASE

(If the case fits more than one type of case, select the most definitive category.) If the most

descriptive label is a subcategory (is indented under a broader category), place an "x" in both

the main category and subcategory boxes.

Condominium

Homestead residential foreclosure SO $50,000

Contracts and indebtedness

Homestead residential foreclosure $50,00 I -$249,999

Eminent domain

Homestead residential foreclosure S250,000 or more

Auto negligence

Nonhomestead residential foreclosu.re

Negligence - other

SO $50,000

Business governance

Nonhomestead residential foreclosure

Business torts

$50,001 - $249,999

EnvironmentallToxic tort

Nonhomestead residential foreclosure

Third party indemnification

$250,000 or more

,_.. f::-'

Other real property actions $0 -~~:s..O~?p'O

Construction defect
-

Premises liability residential

Malpractice - medical

X Real PropertylMortgage Foreclosure

Commercial foreclosure SO .. $50,000

.X_Commercial foreclosure 550,001 - $249,999

Commercial foreclosure 5250,000 or more

IJ

__"

~.

;,.

...-..

:" ;: ~?;

r-~:;.~~
Z
.'

. I

..... " ..

f~,?

.r

U1

Malpractice .. other professional

Other
AntitrustlTrade regulation

Business transactions

Constitutional challenge - statute or ordinance

Constitutional challenge .. proposed amendment .

Libel/Slander

Corporate trusts

Shareholder derivative action

960921

~~I'

=::
':- : ......
:'-~ ::
_,,'

Professional malpractice
Malpractice business

Other real property actions $25~09Q'or mor\~

Premises liability - c~mmercial

Products liability

~~::

Other real property actions 550;00:" $249~9

---

Nursing home negligence

r':

_~

Mass tort
Negligent security

.....

:.=
~ ~-'~ :'::'~
;....
-. (,-.)
( ....

12..02121-2

II.

TYPE OF CASE

(If the case fits more than one type of case, select the most definitive category.) If the most
descriptive label is a subcategory (is indented under 8 broader category), place an "x" in both
the main c~tegory and subcategory boxes.

.'0... . \
.

Condominium

III.

.~

Homestead residential foreclosure $0 $50,000

Discrimination - employment or other

Securities litigation

Insurance claims

Trade secrets

Intel1ectual property

Trust litigation

REMEDIES SOUGHT (check all that apply):

X monetary;
nonmonetary declaratory or injunctive relief;
punitive

IV.

NUMBER OF CAUSES OF ACTION: [

(specify)

IS THIS CASE A CLASS ACTION LAWSUIT?

yes

X no
VI.

HAS NOTICE OF ANY KNOWN RELATED CASES BEEN FILED?

X no

yes If "yes," list all related cases by name, case number, and court.

VII.

IS JURY TRIAL DEMANDED IN COMPLAINT?

yes

X no

d in this cover sheet is accurate to the best of my knowledge and belief.

la. Bar#

Signatu

Attorney or party

0029364

(Bar # if attorney)

Danielle N. Parsons

960921

12-02121-2

Filing # 36473683 E-Filed 01/12/2016 04:13:03 PM

VIA Email gharrell@marioncountyclerk.org

Gregory C. Harrell
General Counsel to David R. Ellspermann
Marion County Clerk of Court & Comptroller
Ocala, Florida 34475

December 24, 2014

RE: Clerks duty and the civil cover sheet (form 1.997), Rule 1.100(c)(2).
Reverse Mortgage Solutions, Inc. vs. Neil J. Gillespie, et al., Case No. 13-115-CAT
Dear Mr. Harrell:
You emailed me December 09, 2014 at 4:59 PM about the civil cover sheet (form 1.997):
-The case was designated as a commercial foreclosure by plaintiff's counsel in the civil
cover sheet that the plaintiff is responsible for preparing and filing at the outset of the
case. You will need to take the matter up with the court and/or the plaintiff however you
deem appropriate if you dispute the plaintiff's characterization of the case, as the Clerk
has no say in that.
Mr. Harrell, under Rule 1.100(c)(2) ...all proceedings in the action shall be abated until a
properly executed cover sheet is completed and filed.... This is the Clerks duty, see
Rule 1.100(c)(2) Pleadings and Motions.
(2) A civil cover sheet (form 1.997) shall be completed and filed with the clerk at the
time an initial complaint or petition is filed by the party initiating the action. If the cover
sheet is not filed, the clerk shall accept the complaint or petition for filing; but all
proceedings in the action shall be abated until a properly executed cover sheet is
completed and filed. The clerk shall complete the civil cover sheet for a party appearing
pro se.
Currently the civil cover sheet (form 1.997) is not properly executed as completed and filed.
The Clerk has a ministerial duty under Rule 1.100(c)(2), ...all proceedings in the action shall be
abated until a properly executed cover sheet is completed and filed..
When can I expect the Clerk to fulfill its ministerial duties under Rule 1.100(c)(2)?
Sincerely,

Neil J. Gillespie
8092 SW 115th Loop
Ocala, Florida 34481

Email: neilgillespie@mfi.net
Phone: 352-854-7807

Enclosures

RULE 1.100

FLORIDA RULES OF CIVIL PROCEDURE

such; an answer to a crossclaim if the answer contains

a crossclaim; a third-party complaint if a person who
was not an original party is summoned as a third-party
defendant; and a third-party answer if a third-party
complaint is served. If an answer or third-party answer contains an affirmative defense and the opposing
party seeks to avoid it, the opposing party shall file
a reply containing the avoidance. No other pleadings
shall be allowed.
(b) Motions. An application to the court for an order shall be by motion which shall be made in writing
unless made during a hearing or trial, shall state with
particularity the grounds therefor, and shall set forth
the relief or order sought. The requirement of writing
is fulfilled if the motion is stated in a written notice of
the hearing of the motion. All notices of hearing shall
specify each motion or other matter to be heard.
(c) Caption.
(1) Every pleading, motion, order, judgment, or
other paper shall have a caption containing the name
of the court, the file number, the name of the first party
on each side with an appropriate indication of other
parties, and a designation identifying the party filing
it and its nature or the nature of the order, as the case
may be. All papers filed in the action shall be styled in
such a manner as to indicate clearly the subject matter of the paper and the party requesting or obtaining
relief.1
(2) A civil cover sheet (form 1.997) shall be completed and filed with the clerk at the time an initial
complaint or petition is filed by the party initiating the
action. If the cover sheet is not filed, the clerk shall
accept the complaint or petition for filing; but all proceedings in the action shall be abated until a properly
executed cover sheet is completed and filed. The clerk
shall complete the civil cover sheet for a party appearing pro se.
(3) A final disposition form (form 1.998) shall be
filed with the clerk by the prevailing party at the time
of the filing of the order or judgment which disposes of
the action. If the action is settled without a court order
or judgment being entered, or dismissed by the parties, the plaintiff or petitioner immediately shall file
a final disposition form (form 1.998) with the clerk.

RULE 1.110

The clerk shall complete the final disposition form for

a party appearing pro se, or when the action is dismissed by court order for lack of prosecution pursuant
to rule 1.420(e).
(d) Motion in Lieu of Scire Facias. Any relief
available by scire facias may be granted on motion
after notice without the issuance of a writ of scire
facias.
1.
E.g., Order Denying Plaintiffs Motion for Summary Judgment, Defendants Motion to Compel, Order Denying Defendants Motion to Dismiss, Final Judgment for Plaintiff, etc.

Committee Notes
1971 Amendment. The change requires a more complete designation of the document that is filed so that it may be more rapidly
identified. It also specifies the applicability of the subdivision to all
of the various documents that can be filed. For example, a motion to
dismiss should now be entitled defendants motion to dismiss the
complaint rather than merely motion or motion to dismiss.
1972 Amendment. Subdivision (a) is amended to make a reply
mandatory when a party seeks to avoid an affirmative defense in
an answer or third-party answer. It is intended to eliminate thereby
the problems exemplified by Tuggle v. Maddox, 60 So. 2d 158 (Fla.
1952), and Dickerson v. Orange State Oil Co., 123 So. 2d 562 (Fla.
2d DCA 1960).
1992 Amendment. Subdivision (b) is amended to require all
notices of hearing to specify the motions or other matters to be
heard.

RULE 1.110. GENERAL RULES OF

PLEADING
(a) Forms of Pleadings. Forms of action and technical forms for seeking relief and of pleas, pleadings,
or motions are abolished.
(b) Claims for Relief. A pleading which sets forth
a claim for relief, whether an original claim, counter
claim, crossclaim, or third-party claim, must state a
cause of action and shall contain (1) a short and plain
statement of the grounds upon which the courts jurisdiction depends, unless the court already has jurisdiction and the claim needs no new grounds of jurisdiction to support it, (2) a short and plain statement of the
ultimate facts showing that the pleader is entitled to
relief, and (3) a demand for judgment for the relief to

CIV-24

Form 1.997 CIVIL COVER SHEET

The civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other
papers as required by law. This form sh~lI~be.fi~d by the plaintiff or petitioner for the use of the Clerk of the Court for the purpose of
reporting judicial workload data pursuanit<Y Ftbrlda Statutes Section 25.075.
CASE STYLE

I.

IN THE CIRCUIT COURT OF THE FIFTH

JUDICIAL CIRCUIT OF FLORIDA IN AND
FOR MARION COUNTY
Plaintiff

Case #
Judge:

REVERSE MORTGAGE SOLUTIONS, INC.

l 3. - \ \ :- L.ea=

vs.
Defendant

II.

NEIL J. GILLESPIE AND MARK GILLESPIE AS CO-TRUSTEES

OF THE GILLESPIE FAMILY LIVING TRUST AGREEMENT
DATED FEBRUARY 10, 1997, et ale
.~ '~"

TYPE OF CASE

(If the case fits more than one type of case, select the most definitive category.) If the most

descriptive label is a subcategory (is indented under a broader category), place an "x" in both

the main category and subcategory boxes.

Condominium

Homestead residential foreclosure SO $50,000

Contracts and indebtedness

Homestead residential foreclosure $50,00 I -$249,999

Eminent domain

Homestead residential foreclosure S250,000 or more

Auto negligence

Nonhomestead residential foreclosu.re

Negligence - other

SO $50,000

Business governance

Nonhomestead residential foreclosure

Business torts

$50,001 - $249,999

EnvironmentallToxic tort

Nonhomestead residential foreclosure

Third party indemnification

$250,000 or more

,_.. f::-'

Other real property actions $0 -~~:s..O~?p'O

Construction defect
-

Premises liability residential

Malpractice - medical

X Real PropertylMortgage Foreclosure

Commercial foreclosure SO .. $50,000

.X_Commercial foreclosure 550,001 - $249,999

Commercial foreclosure 5250,000 or more

IJ

__"

...-..

:" ;: ~?;

r-~:;.~~
Z
.'

f~,?

~.

;,.

. I

..... " ..

.r

U1

Malpractice .. other professional

Other
AntitrustlTrade regulation

Business transactions

Constitutional challenge - statute or ordinance

Constitutional challenge .. proposed amendment .

Libel/Slander

Corporate trusts

Shareholder derivative action

960921

~~I'

=::
':- : ......
:'-~ ::
_,,'

Professional malpractice
Malpractice business

Other real property actions $25~09Q'or mor\~

Premises liability - c~mmercial

Products liability

~~::

Other real property actions 550;00:" $249~9

---

Nursing home negligence

r':

_~

Mass tort
Negligent security

.....

:.=
~ ~-'~ :'::'~
;....
-. (,-.)
( ....

12..02121-2

II.

TYPE OF CASE

(If the case fits more than one type of case, select the most definitive category.) If the most
descriptive label is a subcategory (is indented under 8 broader category), place an "x" in both
the main c~tegory and subcategory boxes.

.'0... . \
.

Condominium

III.

.~

Homestead residential foreclosure $0 $50,000

Discrimination - employment or other

Securities litigation

Insurance claims

Trade secrets

Intel1ectual property

Trust litigation

REMEDIES SOUGHT (check all that apply):

X monetary;
nonmonetary declaratory or injunctive relief;
punitive

IV.

NUMBER OF CAUSES OF ACTION: [

(specify)

IS THIS CASE A CLASS ACTION LAWSUIT?

yes

X no
VI.

HAS NOTICE OF ANY KNOWN RELATED CASES BEEN FILED?

X no

yes If "yes," list all related cases by name, case number, and court.

VII.

IS JURY TRIAL DEMANDED IN COMPLAINT?

yes

X no

d in this cover sheet is accurate to the best of my knowledge and belief.

la. Bar#

Signatu

Attorney or party

0029364

(Bar # if attorney)

Danielle N. Parsons

960921

12-02121-2