FILED: PALM BEACH COUNTY, FL SHARON BOCK, CASE NUMBER: 2014CA013742 DIVISION: AW Filing 20558894 Electronically Filed 11/14/2014 05:31:28 AM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, 3N ANS FOR PALM BEACH COUNTY, FLORIDA SOVEREIGN GAMING 8L LLC, Rlaintit?, V. CASE 3485 LAGO DE TALAVERA TRUST, Befeodaat. MORTGAGE FORECLOSURE COMPLAINT elaintif?, GAMING ENTERTAINMENT, LLC, sues Defendan?s), 3485 LAGG DE TAMVERA TRUST, and any and all parties claiming by, through, under, and against the herein named Defendantls) who are not known to be dead or alive, whether said unknown oarties may Claire ao ioterest as spouses, heirs, devisees, grantees, or other claimants, the oaroes being fictitious to aecoaht for parties in possession, and alleges: 1. This is arr ir: rem action to foreclose a mortgage on real property located and sitoated re Palm Beach County, Fioridag deserioed as follows: Lot 29, of the Plat of TALAVERA 190.8,, according to the Plat thereof, as recorded lo Plat Book 105,, Page as, of the Pabiic Records of Palm Beach County, Florida. 2. On June 12, 2012, there was executed and delivered a Promissory Note (?Mortgage Note?) and a Mortgage (?Mortgage?) securing the payment of the Mortgage Note. The mortgage was recorded or; jane 20, 1012, in Official Records Book 25278, at Page 948, of the Pablie Records of ?alro Beach Coanry; Florida, (All subsequent recordieg refereeces are to the pobiit: records of Petra Beach Coonty, Florida) arid mortgaged the reai and persooai property ("PrOperty?) described therein, then" owned by and in possession of the Mortgagor. A copy of the original Mortgage is attached hereto and incorporated herein as an Exhibit A. 3. 0e {December 29; 2014, aaid mortgage and note were assigned to Plaintiff by an Assigen?ieot of Mortgage which was recorded on Feloroan,r 6, 2014 in Official Records Book 26600,. at Page 1181? A copy of the Assignment of Mortgage is attached hereto as Exhibit 4? Piaintiffia oow the hoidee of the Mortgage Note ("Note?) aod Mortgage and/or is eotitied to enforce the Mortgage Note aod Mortgage. 5. The Property is now owned of record by Defendant. 6. The Mortgage Note and Mortgage are in default, as a result of the transfer of the property by Qoit Claim Seed on Aprii 24, 2013. A copy of said deed is attached as Exhibit C. 7. in additioo, no payments have been made since the making of the Note. 8. Piainti?? deeiares the full amount payable under the Mortgage Note and Mortgage to be now doe. 9. Plaioti?? roost be paid $200,000 in principal on the Mortgage Note and mortgage, together with ietereat at the rate of 4% for the period iene 17, 2012 through April 23; 2012 and at the rate oi18%ior the period April 24, 2013 throogh November 23, 2014, advanees toward paymeot of real prooerty taxes and property owoer assoeiation fees made by Piainti??, property preservation payments, outstanding and unpaid real property taxes, and all costs of collection including title search expenses for ascertaining necessary parties to this action and reasonable attorney?s fees; ail of which are stated in Exhibit attached hereto. 10. Ali to the acceleration of the Mortgage note and foreclosure of the Mortgage have been performed or have occurred. 11. Plaintiff has retained the law firm Siskind Legal Group in this action and is obiigated to pay it a reasonabie fee for its services in bringing this action as well as all costs of eolleetioe. 12. The ieterests of each defendant are subject, subordinate, and inferior to the sight, title, interest, aed liee of Piaintiff?s Mortgage with the exceptioe of any special assessmeets that are supet?or perseant to Flosida Statutes Section 159 {2006) aed Fletida Statutes Section 170.059 (2806), 13. One or more unknown beneficiaries of Defendant may have or claim an interest in the Property that is the subject of this Foreclosure action by virtue of possession, or any right of redemption, air may othemrise claim an interest in the Property, but said rights are inferior to Pia?etiff?. WHEREFORE, Piaint?ff requests that the court ascertain the amount due Plaintiff for principal and intesest at: the Mortgage note and Mortgage and for late charges, abstracting, taxes, expenses aed casts, ?neluding attorney?s fees, pius interest thereon; that if sums due Flaietiff endet the mortgage eote aed mortgage ate eot paid immediately, the Coert foreclese the Mortgage and the Clerk of the Coett sell the Ptoperty secering the indebtedeess to satisfy elaietitf?s mortgage lien in aeeotdance with the provisioes of Florida Statetes Section 45.03: (2006); that the rights, title and interest of any Defendant, or any party claiming by, through, under any defendant named herein or hereafter made a Defendant to be forever barred and foreclosed; that the court retain jurisdiction of this action to make any and all further orders I 'w ., vw aged gadgmeets as may be and emper; inclue??ng the issuagce of a we: of posees?s?en and emey 9f 8 defic?emy decree, when eed if such deficieecv shall appeas pamper, if eerrewerls) has :30: been diseharged En bankruptcy. SOVEREIGN GAMING ENTERTAINMENT, LLC a 525 S. Flagler Drive, Ste. 500 West Palm Beach, Florida 33401 PH: {561) 832-7720 PX: (561) 832~7668 jeffsiskind@msn.com SISKIND LEGAL GROUP Counsel fer Waletlff By: /5/Je?rey M. stkind Jeffrey M. Esq. FL Bar No.138746 ts? EXHIBITA . 20120343192 OR BK 25278 PIES 0948 Prepared by 85 retoro to: RECORDED 06120/2012 12 :22 :30 W01: ESQ. Palm County, Florida :3Qih3ggf 1,6130%} 133:1: Road ART 200' mg. 00 Deed Doc 7700. 00 Boot} Rotor}, FL 33433 Intong ?30? 00. Kg?, 3) $horon E. Book, CLERK a. {9 P912: 0948 .. 950: (33:93) 21> MORTGAGE DEED {to 6 THIS oog'romo DEED, Exocuted the of 2012.13)! cums I my a 59% man, whose post office address is 3 7 We: cohort the Mortgagor, to MICHELLE WATSON, whose posit of?ce address is 8729 gton View More, West Palm Beach, FL 33411., hacinafter collod the Mortgagee: {??amsm that for good and valuable considerations, and also in consideration ofthe aggro?! f?Xsuza named in the promissory note of even date herewith, hereinafter describe? the bargains, sells, aliens, premises, conveys andcon?mts unto the mortgagee a; the cg/E?gfxitmd ofwhich the mortgagor is now seized and in possession situate in Palm Beach County, liloridokv?iz: Lot 291?ng Fiat P.U.D., according to the Plot thereof, as recorded in Plat Page 44, of the Public Records of Palm Beach County, Florida. {r Prooerty Add/fees: ?13485 Logo De Tailor/era, Lake Worth, FL 33467 Parser 9? MI WE MORTGAGE m?g SECURED HEREBY ARE NOT ASSUMABLE AND SHALL BE 3335 ARE) PAYABLE IN SALE OR TRANSFER OF THE SUBJECT REAL PROPERTY. ANB the sonic. together with the tenements, hereditaments and awortenances thereto beiongingi??ai?ic rents, issues and pro?ts thereof, unto the mortgagee, in fee simolo ?2?1 ,r . . . a AND the mortgagor the mortgagee that the mortgagor 18 mdefewbly seized of sale land in fee simple; the mort? ?hag: good right and lawful authority to convey said land as aforcoaid; that the mortgagor wi ll malggioh?mher assurancos to perfect the fee simple title to said 13:16 to the mortgagee as may reasonably be required: that the mortgagor hereby folly warrants the ?tie to said land and will defend the some against the law?ll claims of all persons whomooever; and that said End is ?ee and clear of all encumbrances ALWAYS, that if said mortgagor shall pay unto said mortgagee the certain proo?ssory note sobstantially copied or identi?ed, to-wit: SEE ATTACHED EXHIBIT and shall perform, compiywith and abide by each and every the agreements, stipulations, conditions an? covenants thereof, and ofthis mortgage, then this mortgage and the {mate hereby created, shall cease, determ'me and be null and void. the mortgagor hereby fzmher covenants and agrees to when due the principal and mm and other sums chimney provided for in said note and this mortgage, or either; to pay all and singular the mug, assessments, levies, liabilities, obligations and of every mum: on said omoerty: to permit, commit, or suffer no waste, impairment or deterioration of said land or the improvements theme}; at any time; to keep the buildings now or hereafter on said land fully insorcrt in am ofoot less than We in a company or companies acceptable to the mortgagee, the policy or poiiciee to be held by, and payable to, said mortgagee, and in the event any son: of money becomes payable by virtue ofsuch insurance the mortgagee shall have the right to Book25278/Page948 Page 1 of 3 rmivc am} apply?m some the same to the scoured. accounting to the mortgagor for any surplus; to pay all costs charges: and including lawyer's fees and title searches, :mona?j; mm orymd hy the mortgagor: because ofthc failure oftho mortgagorzo promptiy and foiiy 89:13:33}! with tho agreements, stipulation, conditions and covcnams of said note and this moogage. or either; to ocrfomu comply with and abidc by each and even); tho ,23\ stipuia?ons, oond?ioas and covenants sot fonhin said new and this mortgage or c: the: In the \3 If) the mortgagor fails ?0 paywhon due any tax mom, insurance premium or other sum of money yabiohy vim ofsaid {who and this mortgage: or cithor the: mortgagor: maypay the same, without 13:: $0 waiving or ?oating the: eotioo to foreclose: or any other right hcrcuudcr, and all such shall hm homes: from date amt? at the highmt Iaw?zl rate the nllowal by the laws of Stats of fgyo?m Y?i: 1? any 333333 of money 8min mfmod ?0 be 2:01: 133% within 31 ?ays next sac: the WW becomoo doc, or if ?ash and every the ammonia, s?ooiatioa; conditions and covenanzs of song?? aod this mongogc or either are not foiiy oerfomnod complied with an? aoidod by, then saw zom?onod to soi? note, ms: this mortgage, or the omit: balance :zopai? :hcrcon shall the}; :hm?cr, at tho option of?ac magagee, became and be one and gayabkc anything 1h 52m herein ?9 the {zoom notwithstanding Faiiore by the mortgages. to exercise my of the ?ghts or homo provided shat: not coos?mtc a waiver ofaoy ?ghts or options moor 38% not: or this m?o?gigc accrued or therea?cr accruing IN WHEREOF the said mortgagor: have hereunto signed and scaled that presents tho day/?53 year ?rst above written Sigma}, mled a?tfi?d in the prosoncc of: I t?k?fs GEORGE m: MW STATE OF com or: ?m fomgoiog imam was acknowlodgcd before me: this/211$ of v. . (31115.3 Gwrgo, who is pcmonoily known to me or who has prod as iden??oaxion. Romm Siam 9., a $133? 55,: Q) mum WW3 mamas Book25278/Page949 Page 2 of 3 COPY MORTGAGE NOTE $200,000.00 WW 5'de June .22 ,2012 ?(gag FOR VALUE RECEIVED, the undersigned, ?cintiy and if more than one) 0:3: to pay to MCKELLE WATSON, or order, in the manner hereinafter speci?ed the pa} 50:0 91? TWO WIRED THOUSAND DOLLARS AND 100 DOLLARS 009 00} with mm .0030 date atthe rate of four per cent per annum The said p?acigai am: imam: 3200.9 be payable In Iaw?xl money ofthc United States of America at 8339 ailington View ?rm: Wm "Palm Beach, FL 3301 1 or at 831011 place as may hcm?cr b: (106% by mam 310000 the holdcr to the; makcr hereof, cm the: date and in the manna fe?e?nng?i jig?? gm primiya} 033mm of 5200 009.00 plus accumulated interest shall be due and payabic We a: transfer 0f 09: lowed at 3485 {ago 9: TaEavcm, Lake Worth, $1 3346?? This 30 22:00:03: is max-:0 by a mortgage on 3:31 estate of even date herewith made by {he mkar hat-609m {aver 013010 said paycc am: shail be 090303100 300 0900:0ng to the ?aws af?x 3m: 0&3; {g If dcfauit be I?aiigr?i flit payment 0f any cf 0:0: 50:20: or intmt mm?oned hemin 0r ia Baud mortgage, or the: Wofany ofthc amour: contained hcrefn orfn said mortgage, than the out?t: pnmipal sum?zhgi?ii?faul 1: interest of cightocn shall at the option of the at I agd collectiblc without notice, time being ofthc mac; and said principal sum and accrued WI both bcar interact from such time. until paid at the highest rate allowable: unclear the; 100936? the State of Fiorida. Failure to exercise this option shall not constitute a waiwr ofthc right toGtcise the same in the event ofany subscqucnt dcfault. Each person liable: hemon maker or endorser, hereby waivw protest, noticc, notice of mates: and notiocof/Qi?honor and agrees ta pay all costs, including a (amenable aaomcy?s fee Windham" suit be brought "010% if, after maturity of this antic: or dcfault hereunder or sm?cr said mortgage, commi shall Bk?ia?kwd to 0011ch this note or to the security of 5000 max-{gags and W0 terms ?holder", ?maker? and "payee? sh be construed in singuia?r or pmmi as 03c seam! may rcquirc or admit. Makex?s COPY Book25278/Pa90950 Page 3 of 3 EXHIBIT If. .5. ~14 ?3901 CIR 113K ?2:6;an $1,531. Piepmd by 3M ram is: 123(10an mama/mm 14:54:00; jgf?'ey M0 qu?igg Palm Beach {101mm, Florida . Sharon R. Bock. CLERK 3. C30119THULLER 52% 8. Eagle: Dnve, Ste. 500 P915 110.1 3.182; (21393} mem Beach, FL 33401 Egg/>0 @593 ASSIGNMENT 0F MORTGAGE yams Received, WCHELLE WATSON, the undersigned holder ofa Mortgage (herein does 333mb}; gram, sen, assign, transfer and convey 11mg SOVEREIGN ?a GAMING LLC, a Ficti?a limited Eiahiliiy campany, whesc a?dresg is; 525 Scum Flagiar 13%; Shite 508, West Palm Beach, FL 33401, all bene?ciai interest under that certain Mortgage gaggd belaw together with the netegjs} azad Gb?gations 016mm degarib?z? a and the money due and if @1213 due therean with in?erest aad a1} rights accrued at to accrue; \y :5 "ands: said Me?gage, which was recorded in Palm Beach County, Florida on June: 20, 2012 in {)?iciai Records 8003: 252??at page 948; instrument no. 20120243192. 0 0:3ng lender: 1861 Lane Wezimgohi?? 33414 Originai Bgrrewer: Chris George Bait": of Mortgage: Jam 12, 201?. Property Desc?p?on: L9: 29, of the Plat of TALAVERA P.U.D., according to the Flat thereof, as recorded in Plat Book 105, Page 44, ofthe Pubiic Records of PaJm Beach County, Florida Parcei Centre! Nmbez: 00?4244? 1 9000-0290 Streat Address: 3485 Lago De Talavera, Lake Worth, FL 33414. Original loan Amount: $200,000.00 Book26600lPage1181 Page 1 of 2 this {3f Merigage I S61 my hand this 24?? day ofJanuary, 20M: Assignm?: Yf? Wm y? @ma: 1 ?ago Michelie ?Watsmm Rig} 8729 Weilingion 3313316 West Palm} Beach, FL. 334 My?: BEFOR??gthis 24th day oflanwy, 2014 appwed MICHELLE WATSON idenu?ed me by her Flori?cgd?ver iicensge: which voluntarily af?xed her signature harem in my pregame 41:40 NOTARY PUBLIC STATE OF FLORIDA 6?5) Ba?hoiomcw Case Gamm?xp. fl {'38 cm M. 1, ?iv/?39 w: EXP ass Umambu 29.2614 QMMN Book26600/Page1182 Page 2 of 2 .3 W. W?six W. 2(2) By eed mm BK 26612)?? PG . . . *y ie??rey EVE. Stekmd, ?eemee . ?mm? 0518812613 14:26:: 523 South Strive, Seize 586 Pat: Mach Florida West?aim emu, ii, 334?3l~??390 1e. ea that: Many 6. Tl: 391110 NiiMBBii: E?'zemn It. Honk, CLERK 8. COEPTMLER I 8 ?(29,3 Qnre CLAIM Been a {it} made the 249' eff Aerii 26% between is 3433 Lege Se 'i?aievm Lake Werth Fi, 3346?, called the (Renter anti 3485 Legs De Teiavera 'i?eesL tehese a??ress is efe Siskin? Legal Sewing? 23 giegier ?rive, Seite 390 West i?elm Beach ii}; 334% hereinafter ealieci the Grantee, {mew tit/(ah the (Emitter, the arid 2e eensitleretion ef the sun: of TEEN DQLLARS {$16 {til} hemi $3ng the eaid Grantee the whereof is hereby eekeewietiged {lees hereby remiss: reieesev'eeti quiteiaim unit: the said Grantee ferever, alt the right, title ieterest claim and demand with?) ?13 said Grantor has 111 and to the following described parcel of land, situate lying and being 111 yummy of Palm Beach1 State of FLORIDA to wit: ?15% gt greEE ATTACHED EXHIBIT A We Subject to covenants, restrict10n rm i?Q/x @233 2 a Book26OOT/Page1768 Page 2 of 2 W. Cl 9W w?vhww \y m. w. Oi: AMOUNTS ANSI OWZNG Principal Interest 4% 310 days $210178 interest 18% 568 days 888.0301 Preperty Preservation Costs Paid Reel Estate Taxes Paid April 3, 203,8, YR @2011 Real Estate Taxes Deegw YR 2012 Reel Esiete Taxes {mew YR 2013 Real Estate Taxes Quegw YR 201:8 POA Fees {Jaid Aiti?ii?i?} eys? Fees - fixed fee Filing Fee Process Service Title Search TOTAL 0. 8 i . ?a 200,000.00 6,794.52 56,021.90 12,500.00 9,454.23 5 8,474.71 8,008.78 3 8,098.58 28,108.00 2,500.00 1,900.00 3 125.00 200.00 342,185.72