Filing # 195711562 E-Filed 04/08/2024 03:29:06 PM
`
`
`FREEDOM MORTGAGE CORPORATION
`IN THE CIRCUIT COURT OF THE
`PLAINTIFF,
`NINTH JUDICIAL CIRCUIT, IN AND FOR
`VS.
`ORANGE COUNTY, FLORIDA CIVIL
`CARLOS F. ARAUJO ET AL.,
`DIVISION
`DEFENDANTS.
`CASE NO.: 2023-CA-017903-O
`
`
`
`
`
`MOTION FOR CLERK DEFAULT
`
`
`Plaintiff moves for entry of default in the above styled cause against Defendants, Carlos F.
`Araujo, Ford Motor Credit Company LLC F/K/A Ford Motor Credit Company, A
`Corporation , Cambridge Crossing Phase 1, Phase 1a And Phase 2 Property Owners
`Association, Inc., Heather D. Hall and Unknown Tenant In Possession Of The Subject
`Property, for failure to file or serve a pleading or other paper within the time required by law.
`
` I
`
` HEREBY CERTIFY that a true copy of the foregoing and an Affidavit as to Military Status
`was delivered to the parties on the attached service list by mail/email this 8th day of April 2024.
`
`
`
`Miller, George & Suggs, PLLC
`210 N. University Drive, Suite 900
`Coral Springs, FL 33071
`Telephone: 786-268-9954
`DESIGNATED PRIMARY EMAIL FOR SERVICE
`PURSUANT TO FLA. R. JUD. ADMIN 2.516:
`ESERVICE@MGS-LEGAL.COM
`
`
`
`
`
`
`
`
`By: /s/ Karen A. Green___
`
`Karen Green
`Bar No. 628875
`
`
`
`23FL373-0866
`
`
`
`

`

`CIRCUIT Court
`
`RETURN OF NON-SERVICE
`County of Orange
`State of Florida
`Case Number: 2023-CA-017903-O Court Date: 12/28/2023
`Plaintiff: FREEDOM MORTGAGE CORPORATION
`vs.
`Defendant: CARLOS F. ARAUJO, ET AL.,
`For:
`Aamir Saeed
`MILLER, GEORGE & SUGGS PLLC
`2200 West Commercial Blvd
`Suite 103
`Ft. Lauderdale, FL 33309
`Received by Z PROCESS SERVICE, INC on the 28th day of December, 2023 at 5:08 pm to be served on
`HEATHER D. HALL, 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787.
`I, Holly Vicens, do hereby affirm that on the 2nd day of February, 2024 at 4:45 pm, I:
`NON-SERVED the SUMMONS, NOTICE OF LIS PENDENS, VERIFIED COMPLAINT, EXHIBITS, AND
`CERTIFICATION OF POSSESSION OF ORIGINAL NOTE, CASE MANAGEMENT ORDER for the
`reason that I failed to find HEATHER D. HALL or any information to allow further search. Read the
`comments below for further details.
`
`ZPS2023033472
`
`Additional Information pertaining to this Service:
`1/4/2024 10:36 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access gated neither names in call box,very small neighborhood with no place to wait for incoming traffic
`1/6/2024 1:11 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access this is going to be really hard to get into,very very little traffic and no where to wait
`1/10/2024 6:25 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no answer no lights on one vehicle cant see tag
`1/16/2024 10:16 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL
`34787 no access
`1/16/2024 6:14 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/22/2024 7:36 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/29/2024 1:05 pm Attempted Service. 2730 MCQUEEN RD, APOPKA, FL 32706 Unknown at this location
`home is occupied for the past 30 years by the same owner.
`1/31/2024 4:19 pm Attempted Service at 5045 DOWN POINT LN, WINDEREMERE FL 34786 Per Carlos
`she works at Circle K /P on Keene rd. Do not have full address.
`2/2/2024 4:43 pm Non-Serve
`
`

`

`RETURN OF NON-SERVICE For 2023-CA-017903-O
`
`I do hereby certify that I have no interest in the above action, that I am over the age of eighteen, and that I
`am a Certified Process Server in the Judicial Circuit in which it was served. Under penalties of perjury, I
`declare that I have read the forgoing affidavit and that the facts stated in it are true. No Notary required
`Pursuant to F.S. 92.525 (2)
`
`Holly Vicens
`0154
`Z PROCESS SERVICE, INC
`8750 NW 36TH STREET
`SUITE 670
`MIAMI, FL 33178
`(786) 205-7483
`Our Job Serial Number: ZPS-2023033472
`Ref: 23FL373-0866
`
`

`

`CIRCUIT Court
`
`ZPS2023033468
`
`RETURN OF SERVICE
`County of Orange
`State of Florida
`Case Number: 2023-CA-017903-O Court Date: 12/28/2023
`Plaintiff: FREEDOM MORTGAGE CORPORATION
`vs.
`Defendant: CARLOS F. ARAUJO, ET AL.,
`For:
`Aamir Saeed
`MILLER, GEORGE & SUGGS PLLC
`2200 West Commercial Blvd
`Suite 103
`Ft. Lauderdale, FL 33309
`Received by Z PROCESS SERVICE, INC on the 28th day of December, 2023 at 5:08 pm to be served on
`CARLOS F. ARAUJO, 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787.
`I, Edwin Young, do hereby affirm that on the 30th day of January, 2024 at 10:26 am, I:
`INDIVIDUALLY/PERSONALLY served by delivering a true copy of the SUMMONS, NOTICE OF LIS
`PENDENS, VERIFIED COMPLAINT, EXHIBITS, AND CERTIFICATION OF POSSESSION OF
`ORIGINAL NOTE, CASE MANAGEMENT ORDER with the date and hour of service endorsed thereon by
`me, to: CARLOS F. ARAUJO at the address of: 5045 DOWN POINT LN, WINDERMERE, FL 34786, and
`informed said person of the contents therein, in compliance with state statutes.
`Military Status: Based upon inquiry of party served, Defendant is not in the military service of the United
`States of America.
`Marital Status: Based upon inquiry of party served, Defendant is not married.
`Additional Information pertaining to this Service:
`1/4/2024 10:35 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access gated neither names in call box,very small neighborhood with no place to wait for incoming traffic
`1/6/2024 1:10 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access this is going to be really hard to get into,very very little traffic and no where to wait
`1/10/2024 6:24 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no answer no lights on one vehicle cant see tag
`1/16/2024 10:15 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL
`34787 no access
`1/16/2024 6:14 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/22/2024 7:36 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/26/2024 1:28 pm Attempted Service at 1973 CORPORATE SQ, LONGWOOD, FL 32750 is a business
`address, doors is locked, no lights on inside, no company name on door or building.
`1/26/2024 4:40 pm Attempted Service at , 4005 MOORINGS LN, ORLANDO, FL 32810 No light, no cars,
`nobody to door, dog inside. VW Bug under car cover in side yard.
`1/30/2024 11:50 am Attempted Service. 5401 S KIRKMAN RD, ORLANDO, FL 32819 . This is an office
`building, missing suite number
`1/31/2024 4:12 pm THIS IS NOT A MOBILE HOME
`Description of Person Served: Age: 48, Sex: M, Race/Skin Color: M, Height: 6'5, Weight: 275, Hair:
`BROWN, Glasses: N
`
`

`

`RETURN OF SERVICE For 2023-CA-017903-O
`
`I do hereby certify that I have no interest in the above action, that I am over the age of eighteen, and that I
`am a Certified Process Server in the Judicial Circuit in which it was served. Under penalties of perjury, I
`declare that I have read the forgoing affidavit and that the facts stated in it are true. No Notary required
`Pursuant to F.S. 92.525 (2)
`
`Edwin Young
`CPS # 0178
`Z PROCESS SERVICE, INC
`8750 NW 36TH STREET
`SUITE 670
`MIAMI, FL 33178
`(786) 205-7483
`Our Job Serial Number: ZPS-2023033468
`Ref: 23FL373-0866
`
`

`

`State of Florida
`State of Florida
`
`County of Orange
`County of Orange
`
`CIRCUIT Court
`CIRCUIT Court
`
`RETURN OF SERVICE
`RETURN OF SERVICE
`
`Case Number: 2023-CA-017903-O
`Case Number: 2023-CA-017903-O
`
`Plaintiff:
`Plaintiff:
`FREEDOM MORTGAGE CORPORATION
`FREEDOM MORTGAGE CORPORATION
`vs.
`vs.
`Defendant:
`Defendant:
`CARLOS F. ARAUJO, ET AL.,
`CARLOSF. ARAUJO,ETAL.,
`For:
`For:
`Aamir Saeed
`Aamir Saeed
`MILLER, GEORGE & SUGGS PLLC
`MILLER, GEORGE & SUGGS PLLC
`2200 West Commercial Blvd
`2200 West Commercial Blvd
`Suite 103
`Suite 103
`Ft. Lauderdale, FL 33309
`Ft. Lauderdale, FL 33309
`
`Received by Z PROCESS SERVICE INC. on the 28th day of December, 2023 at 5:06 pm to be served on CAMBRIDGE
`Received by Z PROCESS SERVICE INC. on the 28th day of December, 2023 at 5:06 pm to be served on CAMBRIDGE
`CROSSING PHASE 1, PHASE 1A AND PHASE 2 PROPERTY OWNERS ASSOCIATION, INC. PROPERTY MANAGEMENT
`CROSSING PHASE 1, PHASE 1A AND PHASE 2 PROPERTY OWNERSASSOCIATION, INC. PROPERTY MANAGEMENT
`OF AMERICA LLC D.B.A. EXTREME MANAGEMENT TEAM C/O EXTREME MANAGEMENT TEAM, 2113 RUBY RED
`OF AMERICALLC D.B.A. EXTREME MANAGEMENT TEAM C/O EXTREME MANAGEMENT TEAM, 2113 RUBY RED
`BLVD. SUITE B, CLERMONT, FL 34714.
`BLVD. SUITE B, CLERMONT,FL 34714.
`
`I, Ashley Nunez, do hereby affirm that on the 2nd day of January, 2024 at 11:54 am, I:
`|, Ashley Nunez, do herebyaffirm that on the 2nd day of January, 2024 at 11:54 am, I:
`
`served a CORPORATE REGISTERED AGENT by delivering a true copy of the SUMMONS, NOTICE OF LIS PENDENS,
`served a CORPORATE REGISTERED AGENT bydelivering a true copy of the SUMMONS, NOTICE OF LIS PENDENS,
`VERIFIED COMPLAINT, EXHIBITS, AND CERTIFICATION OF POSSESSION OF ORIGINAL NOTE, CASE MANAGEMENT
`VERIFIED COMPLAINT, EXHIBITS, AND CERTIFICATION OF POSSESSION OF ORIGINAL NOTE, CASE MANAGEMENT
`ORDER with the date and hour of service endorsed thereon by me, to: DIANA KLEIN as DIRECTOR OF FINANCE at the address
`ORDER with the date and hourof service endorsed thereon by me, to: DIANA KLEIN as DIRECTOR OF FINANCE at the address
`of: 2113 RUBY RED BLVD. SUITE B, CLERMONT, FL 34714 on behalf of CAMBRIDGE CROSSING PHASE 1, PHASE 1A AND
`of: 2113 RUBY RED BLVD. SUITE B, CLERMONT,FL 34714 on behalf of CAMBRIDGE CROSSING PHASE 1, PHASE 1A AND
`PHASE 2 PROPERTY OWNERS ASSOCIATION, INC., and informed said person of the contents therein, in compliance with state
`PHASE 2 PROPERTY OWNERSASSOCIATION, INC., and informed said person of the contents therein, in compliance with state
`statutes. 48.081(3)(a)
`statutes. 48.081(3)(a)
`
`Description of Person Served: Age: 60, Sex: F, Race/Skin Color: WHITE, Height: 5'6", Weight: 180, Hair: BROWN, Glasses: N
`Description of Person Served: Age: 60, Sex: F, Race/Skin Color: WHITE, Height: 5'6", Weight: 180, Hair: BROWN, Glasses: N
`
`I certify that I am over the age of 18, have no interest in the above action, and have been properly certified as a process s erver by
`| certify that | am over the age of 18, have nointerest in the above action, and have been properly certified as a process s erver by
`Administrative Order A200821B and am currently certified to serve process pursuant to the provisions of the order. Under pena lty of
`Administrative Order A200821B and am currently certified to serve process pursuantto the provisions of the order. Under penalty of
`perjury I declare that the facts contained herein are true to the best of my knowledge.
`perjury | declare that the facts contained herein are true to the best of my knowledge.
`
`Ashley Nunez
`Ashley Nunez
`101819-4
`101819-4
`
`Z PROCESSSERVICE INC.
`Z PROCESS SERVICE INC.
`8750 NW 36TH STREET
`8750 NW 36TH STREET
`SUITE 670
`SUITE 670
`MIAMI, FL 33178
`MIAMI, FL 33178
`(305) 463-0040
`(305) 463-0040
`
`Our Job Serial Number: ZPS-2023033469
`Our Job Serial Number: ZPS-2023033469
`Ref: 23FL373-0866
`Ref: 23FL373-0866
`
`Copyright © 1992-2024 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2k
`Copyright © 1992-2024 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2k
`
`

`

`RETURN OF NON-SERVICE For 2023-CA-017903-O
`
`I do hereby certify that I have no interest in the above action, that I am over the age of eighteen, and that I
`am a Certified Process Server in the Judicial Circuit in which it was served. Under penalties of perjury, I
`declare that I have read the forgoing affidavit and that the facts stated in it are true. No Notary required
`Pursuant to F.S. 92.525 (2)
`
`Edwin Young
`CPS # 0178
`Z PROCESS SERVICE, INC
`8750 NW 36TH STREET
`SUITE 670
`MIAMI, FL 33178
`(786) 205-7483
`Our Job Serial Number: ZPS-2023033470
`Ref: 23FL373-0866
`
`

`

`RETURN OF SERVICE
`
`State of Florida
`
`County of Orange
`
`CIRCUIT Court
`
`Case Number: 2023-CA-017903-O Court Date: 12/28/2023
`
`Plaintiff:
`FREEDOM MORTGAGE CORPORATION
`vs.
`Defendant:
`CARLOS F. ARAUJO, ET AL.,
`
`For:
`Aamir Saeed
`MILLER, GEORGE & SUGGS PLLC
`2200 West Commercial Blvd
`Suite 103
`Ft. Lauderdale, FL 33309
`
`Received by Z Process Service, Inc on the 28th day of December, 2023 at 12:31 pm to be served on FORD
`MOTOR CREDIT COMPANY A/K/A FORD MOTOR CREDIT COMPANY LLC C T CORPORATION
`SYSTEM, REGISTERED AGENT, 1200 SOUTH PINE ISLAND ROAD, PLANTATION, FL 33324.
`
`I, DOUGLAS NELSON (FTL), do hereby affirm that on the 2nd day of January, 2024 at 3:18 pm, I:
`
`served a CORPORATION by delivering a true copy of the SUMMONS, NOTICE OF LIS PENDENS,
`VERIFIED COMPLAINT, EXHIBITS, AND CERTIFICATION OF POSSESSION OF ORIGINAL NOTE,
`CASE MANAGEMENT ORDER with the date and hour of service endorsed thereon by me, to: MONICKA
`CREARY as INTAKE SPEC for FORD MOTOR CREDIT COMPANY A/K/A FORD MOTOR CREDIT
`COMPANY LLC C T CORPORATION SYSTEM, REGISTERED AGENT at the address of: 1200 SOUTH
`PINE ISLAND ROAD, PLANTATION, FL 32301, and informed said person of the contents therein, in
`compliance with state statutes.
`
`I certify that I am over the age of 18, have no interest in the above action, and am a Certified Process
`Server or an Appointed Process Server in good standing in the judicial circuit in which the process was
`served. Under Penalty of Perjury I declare that I have read the foregoing Return of Service and that the
`facts stated in it are true and correct. Notary not required pursuant to F.S. 92.525.
`
`DOUGLAS NELSON (FTL)
`Process Server #773 (Broward)
`
`Z Process Service, Inc
`8750 NW 36th Street
`Suite 670
`Miami, FL 33178
`(305) 463-0040
`
`Our Job Serial Number: ZPS-2023033471
`Ref: 23FL373-0866
`
`Copyright © 1992-2024 DreamBuilt Software, Inc. - Process Server's Toolbox V8.2r
`
`

`

`AFFIDAVIT OF AVOIDANCE
`County of Orange
`
`CIRCUIT Court
`
`State of Florida
`Case Number: 2023-CA-017903-O
`Plaintiff: FREEDOM MORTGAGE CORPORATION
`vs.
`Defendant: CARLOS F. ARAUJO, ET AL.,
`For:
`Aamir Saeed
`MILLER, GEORGE & SUGGS PLLC
`2200 West Commercial Blvd
`Suite 103
`Ft. Lauderdale, FL 33309
`Received by Z PROCESS SERVICE, INC on the 28th day of December, 2023 at 5:08 pm to be served on
`UNKNOWN TENANT IN POSSESSION OF THE SUBJECT PROPERTY, 12513 SCARLETT SAGE
`COURT, WINTER GARDEN, FL 34787.
`I, PHILIP J. DENNINGTON, do hereby affirm that on the 22nd day of January, 2024 at 9:36 am, I:
`NON-SERVED AVOIDER the SUMMONS, NOTICE OF LIS PENDENS, VERIFIED COMPLAINT,
`EXHIBITS, AND CERTIFICATION OF POSSESSION OF ORIGINAL NOTE, CASE MANAGEMENT
`ORDERfor the reason that UNKNOWN TENANT IN POSSESSION OF THE SUBJECT PROPERTY is
`avoiding service of process. Read the comments below for further details.
`
`ZPS2023033473
`
`Additional Information pertaining to this Service:
`1/4/2024 10:37 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access gated neither names in call box,very small neighborhood with no place to wait for incoming traffic
`1/6/2024 1:11 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access this is going to be really hard to get into,very very little traffic and no where to wait
`1/10/2024 6:26 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no answer no lights on one vehicle cant see tag
`1/16/2024 10:16 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/16/2024 6:15 pm Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/22/2024 7:36 am Attempted service at 12513 SCARLETT SAGE COURT, WINTER GARDEN, FL 34787
`no access
`1/22/2024 9:35 am This is not a mobile home.
`1/22/2024 9:36 am Non-Serve
`
`I do hereby certify that I have no interest in the above action, that I am over the age of eighteen, and that I
`am a Certified Process Server in the Judicial Circuit in which it was served. Under penalties of perjury, I
`declare that I have read the forgoing affidavit and that the facts stated in it are true. No Notary required
`Pursuant to F.S. 92.525 (2)
`
`PHILIP J. DENNINGTON
`CPS #0161
`Z PROCESS SERVICE, INC
`8750 NW 36TH STREET
`SUITE 670
`MIAMI, FL 33178
`(786) 205-7483
`Our Job Serial Number: ZPS-2023033473
`Ref: 23FL373-0866
`
`

`

`CERTIFICATE OF SERVICE
`
`
`
` A
`
` copy of the foregoing was served via first class U.S. Mail and/or e-service on or about April 8,
`2024 to the parties listed below:
`
`
`
`
`
`
`By: /s/ Karen A. Green
`
`Karen Green
`Bar No. 628875
`
`
`
`
`
`
`FORD MOTOR CREDIT COMPANY LLC F/K/A FORD MOTOR CREDIT COMPANY, A
`CORPORATION
`C T CORPORATION SYSTEM, REGISTERED AGENT
`1200 SOUTH PINE ISLAND ROAD
`PLANTATION FL 33324
`
`CAMBRIDGE CROSSING PHASE 1, PHASE 1A AND PHASE 2 PROPERTY OWNERS
`ASSOCIATION, INC.
`PROPERTY MANAGEMENT OF AMERICA LLC D.B.A. EXTREME MANAGEMENT
`TEAM
`C/O EXTREME MANAGEMENT TEAM
`2113 RUBY RED BLVD. SUITE B
`CLERMONT FL 34714
`
`HEATHER D. HALL
`12513 SCARLETT SAGE COURT
`WINTER GARDEN FL 34787
`
`CARLOS F. ARAUJO
`5045 DOWN POINT LN
`WINDERMERE FL 34786
`
`UNKNOWN TENANT IN POSSESSION OF THE SUBJECT PROPERTY
`12513 SCARLETT SAGE COURT
`WINTER GARDEN FL 34787
`
`HEATHER D. HALL
`5045 DOWN POINT LN
`WINDEMERE FL 34786
`
`
`23FL373-0866
`
`
`
`