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UNITED STATES DISTRICT COURT

FOR THE MIDDLE DISTRICT OF FLORIDA


ORLANDO DIVISION

ABDIEL ECHEVERRIA and


ISABEL SANTAMARIA
Plaintiffs,

CASE NO: 6:14-cv-00486-CEM-DAB

v.
BANK OF AMERICA, N.A., URBAN
SETTLEMENT SERVICES d/b/a URBAN
LENDING SOLUTIONS and CARLISLE & GALLAGHER
CONSULTING GROUP, INC.
Defendants,
________________________/

PLAINTIFFS OBJECTION TO ORDER (DOC. 79) GRANTING DEFENDANTS


MOTION TO STAY PRE-TRIAL DEADLINES OR ALTERNATIVELY, TO STAY
DISCOVERY UNTIL THE PLEADINGS ARE CLOSED
What was initially supposed to be Plaintiffs Opposition to Defendants Motion to Stay
has now transitioned into an Objection to Magistrate Judge David A. Bakers Court Order (Doc.
79). The Plaintiffs received via U.S. mail Defendants Motion to Stay on November 5, 2014, the
same day that magistrate judge Baker granted the Motion to Stay which the Plaintiffs happened
to stumble across on Pacer. Even if the Plaintiffs were able to view the Motion to Stay on time,
their Opposition would have clearly arrived after Judge Bakers swift Order since they are not
able to file electronically.

The Plaintiffs were never allowed the opportunity to oppose the motion to stay in
violation of their due process rights especially given the fact that they are pro se and do not
have the capability to file electronically. Nonetheless, the Plaintiffs will rightfully incorporate
what they had planned to file in their Opposition to the Defendants Motion to Stay in this
Objection to Order [Doc. 79].
Local Rule 3.01(b) clearly states: Each party opposing a motion or application shall file
within fourteen (14) days after service of the motion or application a response that includes a
memorandum of legal authority in opposition to the request, all of which the respondent shall
include in a document not more than twenty (20) pages.
The Plaintiffs were not even granted hours let alone 14 days to file their opposition
when clearly they should have been given the opportunity to state their argument to this
malicious ploy by the Defendants. The Plaintiffs rights continue to be violated by the
magistrate judges of this court in this current action. The Motion to Stay was clearly an
opposed motion so, on what grounds was this motion granted? On record, where is the verbage
on this Order [Doc. 79] for which the Plaintiffs or this court can use as a guide on the grounds
that this Motion for Stay by the Defendants was granted? This Order clearly violates the rules of
this Court and the rights of a litigant.
The Defendants and their counsel continue to be allowed free passes and to play dirty and
this is continuously ignored when the Plaintiffs have notified this Court in their motions and
responses because the magistrates have quickly taken matters into their own hands issuing orders
and reports before the presiding judge can see what is actually going on and this behavior should
not be allowed to continue in a court of law. The Defendants in this case have clearly utilized the
magistrate judges of this Court to their advantage and the magistrates have allowed them to do

so which is against the oath of a United States judge1. The Plaintiffs have been extremely patient
but enough is enough. The Plaintiffs never wanted their case heard in federal court (for obvious
reasons) and all they seek is justice which is what is expected in a court of law, not to be
discriminated by repetitive judicial abuse and corruption in this federal court.
Due to the corrupt nature of these proceedings, it is imperative that these issues be
reviewed only by the presiding judge in this case. It is also in the best interest of justice and of
this court, that Honorable Chief Judge Anne C. Conway be notified of the judicial corruption that
is being conspired between the magistrates of this court, the Defendants and their counsel and the
Plaintiffs may have to take further action if necessary. The Plaintiffs refuse to have their cases
further contaminated by this corruption.
Therefore, the Plaintiffs respectfully request that this Court VACATE the erroneous
Order [Doc. 79] without grounds issued by Magistrate Judge David A. Baker and that the
Defendants Motion to Stay [Doc. 77] be DENIED for the reasons that follow.

LEGAL STANDARD
1. Magistrate Judges Order
Federal Rule of Civil Procedure 72(a) implements 28 U.S.C. 636(b)(1)(A), authorizing
a party to serve objections within 14 days of any magistrate judges order on non-dispositive
matters referred to a magistrate judge from a district judge. Fed. R. Civ. P. 72(a), 28 U.S.C.
636.

28 U.S. Code 453 - Oaths of justices and judges.

Under Rule 72(a), the District Court may consider and shall modify or set aside any
portion of the Magistrate Judges Order found to be clearly erroneous or contrary to law.
Furthermore, the magistrate judges order is not final. See Title 28 U.S.C. 636 (b),(c) & 1291;
and Perez-Prego v. Alachua County Clerk of Court, 148 F. 3d 1272, 1273 (11th Cir. 1998).
2. Motion to Stay
A motion to stay discovery is tantamount to a request for a protective order prohibiting
or limiting discovery pursuant to Rule 26(c), Fed. R. Civ. P. See Kron Med. Corp. v. Groth, 119
F.R.D. 636, 637 (M.D.N.C. 1988). Such motions are not favored, because when discovery is
delayed or prolonged it can cause unnecessary litigation expenses and difficulties, and can create
case management problems that impede the courts responsibility to expedite discovery. See
Simpson v. Specialty Retail Concepts, Inc., 121 F.R.D. 261, 263 (M.D.N.C. 1988).
When ruling on motions to stay discovery, Courts in this District have held that
[m]otions to [s]tay discovery may be granted pursuant to Rule 26(c), Fed. R. Civ. P., and the
moving party bears the burden of showing good cause and reasonableness. Feldman v. Flood,
176 F.R.D. 651, 652 (M.D. Fla. 1997) (citing Howard v. Galesi, 107 F.R.D. 348 (S.D.N.Y.
1985)). Moreover, such motions are not favored because when discovery is delayed or
prolonged it can create case management problems which impede the Court's responsibility to
expedite discovery and cause unnecessary litigation expenses and problems. Id. (citing Kron
Medical Corp. v. Groth, 119 F.R.D. 636 (M.D.N.C. 1988)). Finally, the Court ordinarily should
not stay discovery which is necessary to gather facts in order to defend against the motion. Id.
(citing Wilderness Soc. v. Griles, 824 F.2d 4 (D.C. Cir. 1987); Panola Land Buyers Ass'n v.
Shuman, 762 F.2d 1550 (11th Cir. 1985)).
Discovery may proceed while motions to dismiss are pending in federal litigation, unless
the action is governed by the PSLRAs automatic stay of discovery or a discretionary stay has

been imposed for good cause under Rule 26(c) of the FRCP. The FRCP has no specific
provision about the availability of discovery during the pendency of a motion to dismiss. Rule
26(d)(1) is the only federal rule to specifically address the timing of discovery and it does not
provide that a motion to dismiss must be decided, or even filed, before discovery commences. It
provides that discovery may be taken at any time after the completion of the initial discovery
conference mandated by Rule 26(f).
Indeed, Rule 12(i) provides that a court may defer resolving a motion to dismiss until
trial. The mere filing of a case-dispositive motion does not constitute good cause. At least ten
(10) similar but non-identical multi-factor tests have been devised by federal district courts to
determine good cause in connection with Rule 26(c). Most of the tests focus on the prejudice
to the party opposing the stay (even though the Plaintiffs in this current case were not given the
opportunity to file an opposition to the stay) and the burden on the party resisting discovery.
But a pending motion to dismiss is not ordinarily a situation that in and of itself would
warrant a stay of discovery. . . .10A Federal Procedure, Lawyers Edition 26:337 (2011).
Motions to stay discovery so that a court may rule on a motion to dismiss are not favored,
since they may create case management problems which impede the Court's responsibility to
expedite discovery and cause unnecessary litigation expenses and problems. Feldman v. Flood,
176 F.R.D. 651, 652 (M.D. Case 2:11-cv-00224-MHT -WC Document 49 Filed 08/15/11 Page
25 of 3326 Fla. 1997) (quoting Simpson v. Specialty Retail Concepts, Inc., 121 F.R.D. 261, 263
(M.D.N.C. 1988)). On motions to stay discovery, the moving party must bear the burden and
show good cause and reasonableness for any stay. McCabe v. Foley, 233 F.R.D. at 685.
Defendants have not shown good cause for a stay.

ARGUMENT AND INCORPOARTED MEMORANDUM OF LAW


The Motion to Stay [Doc. 77] brought by the Defendants, is yet another attempt to
forestall consideration of the substantial merits of the Plaintiffs claims and for the purpose of
intentionally suppressing evidence. In contrast, Plaintiffs promptly initiated discovery, filed
their initial disclosures appropriately, filed their expert witness report on October 1, 2014 and
have served their First Set of Interrogatories on all Defendants by October 29, 2014.
Defendant BANA, did not oppose Plaintiffs Second Motion For Leave to File Complaint
[Doc.60], did not even comply with the rules of this court or with the rules of discovery2 when it
filed its Initial Disclosures for which the Plaintiffs filed a Motion to Compel (Doc.69) which was
wrongfully denied by Judge Kelly and yet Judge Baker graciously and swiftly approves the
Defendants Motion to Stay without explanation or allowing the Plaintiffs any time to oppose it.
On October 31, 2014, Plaintiff Isabel Santamaria receives a call at home from BANAs
attorney Sahily Serradet at 2:04pm from telephone number (305) 379-3684. In this conversation,
Ms. Serradet starts by mentioning that all named defendants received the interrogatories and then
later states that she is also calling to confer to see if the Plaintiffs agree to a Motion to Stay. Mrs.
Santamaria refused and said that she would oppose the motion. She also said that she would have
her husband, Plaintiff Abdiel Echeverria, email her confirming that he would also oppose the
Motion to Stay. Mrs. Santamaria also expressed on this call that they were aware of all the dirty
tactics of the Defendants during litigation.
Plaintiff Abdiel Echeverria sent Ms. Serradet the email opposing the Motion to Stay on
October 31, 2014 to at 4:32pm stating: Sahily, This is to advise that I also oppose the Motion to

Fed. R. Civ. P. Rule 26 and 37. Also see Plaintiffs Motion to Compel Doc. 69.

Stay Discovery. Thank you. Ms. Serradet acknowledged the email at 4:40pm which she also cc:
to her colleague Marc Parrino: Noted. Thank you3.
Ironically, Ms. Serradet or any of the other Defendants attorneys did not submit notice to
the Plaintiffs of the electronic filing. Even though the Motion to Stay mentioned at closing that
Defendant BANAs counsel conferred with the Plaintiffs and that the Plaintiffs were opposing
the motion, Judge Baker issued the Order without an explanation or on what grounds it was
granted. The Defendants, we are sure, dont mind. Nonetheless, the injustice continues.
The Plaintiffs have had to deal with intimidation and hints of behind the scenes
accomplishments by the opposing counsel in prior litigation and in this current case. During the
Case Management Conference in May 2014, Mr. Marc T. Parrino arrogantly states: We are just
waiting for this case to be dismissed any day now. Other arrogant comments were also stated
during this meeting from counsel. The Plaintiffs had a very bad vibe about everything that was
going on and their instincts have proven them right so far.
Regardless, to prevail on a motion to stay discovery under F.R.C.P. 26(c), the movants
must show that they will suffer prejudice or undue burden. See Fed. R. Civ. P. 26(c); Rivera v.
NIBCO, Inc., 364 F.3d 1057, 1063 (9th Cir. 2004). The only ones who will suffer prejudice by
this Motion to Stay will be the Plaintiffs who have complied with the rules of this court, have
consistently been criminally bamboozled by the defendants, have suffered on-going fraud, and
have been defrauded in prior litigation. The Plaintiffs have proceeded with all deadlines and have
timely filed all required discovery requests and have also incurred expenses during litigation
even though Mrs. Santamaria is no longer employed due to the defendants illegal actions. The
Defendants on the other hand were suspiciously dormant for quite some time after discovery
3

The email is readily available at the Courts request.

already commenced but were obviously busy little bees behind the scenes. Judge Kellys Report
& Recommendation [Doc. 68] conveniently popped up all of a sudden at the right moment
during the Defendants dormant stage on September 23, 2014. A welcomed miracle, if you
will, for the Defendants.
The Defendants conveniently defend Judge Kellys Report & Recommendation which
was clearly biased and one-sided and failed to address any of the Plaintiffs allegations of
fraud during litigation, new causes of action, on-going fraud, new evidence or the violations that
occurred after all prior claims were dismissed. Judge Kellys Report and Recommendation took a
detour to BANA Land and completely avoided the obvious facts and evidence of this current
case. The Plaintiffs properly and timely opposed this report and recommendation.
The Defendants erroneously contend that by the Plaintiffs rightfully opposing this biased
Report & Recommendation with an Opposition [Doc. 71], the defendants lost almost one month
of preparation time while the Report & Recommendation was pending before the court. Who are
they trying to fool? It seems that the defendants expected something to happen erroneously in
their favor and decided to hold everything instead. If the defendants decided to hold everything
based on the reliance of this new tactic of Judge Kelly to assist them, that is not the Plaintiffs
fault that the defendants collectively did not do their due diligence as required. After all, the
Defendants do have counsel unlike the Plaintiffs. However, the pro se Plaintiffs were still
continuing with discovery as planned by submitting their expert witness report on October 1,
2014 (after the R&R was filed) and preparing their interrogatories while the Report &
Recommendation and their other responses were pending.

I.

THE DEFENDANTS HAVE FAILED TO SHOW GOOD CAUSE FOR


STAYING DISCOVERY
The Defendant have failed to demonstrate the requisite good cause for staying

discovery pending the resolution of their Motions to Dismiss. Normally, discovery commences
after the parties have conferred under Rule 26(f), and the pendency of a motion to dismiss or
their forceful request to close the Plaintiffs pleadings will not justify a stay of discovery. FED.
R. CIV. P. 26(d); see also S.D. Fla. L.R., app. A. at 105.
While the Court may issue a protective order staying discovery for good cause under
Rule 26(c), [s]uch motions for stay are generally denied except where a specific showing of
prejudice or burdensomeness is made, or where a statute dictates that a stay is appropriate or
mandatory. S.D. Fla. L.R., App. A. at 105; see Gannon v. Flood, No. 08-60059-CIV, 2008 WL
793682, at *1 (S.D. Fla. Mar. 24, 2008). No statute requires a stay in this case. Therefore, the
Movants bear the burden of showing good cause for staying discovery. S.K.Y. Mgmt. LLC v.
Greenshoe, Ltd., No. 06-21722-CIV, 2007 WL 201258, at *1 (S.D. Fla. Jan. 24, 2007); In re
Winn Dixie Stores, No. 3:04-cv-194-J-33MCR, 2007 WL 1877887, at *1 (M.D. Fla. Jun. 28,
2007).
The Defendants are trying to force closure of a case, that as a matter of law, should not be
closed and the Plaintiffs will have more than sufficient legal standing for appeal, if need be. The
Defendants continue to erroneously contend that this is the Plaintiffs third attempt to re-litigate
matters addressed and dismissed in Echeverria I and Echeverria II. For the sake of justice, the
Plaintiffs are hoping that their complaints and evidence are actually viewed in this current case
and not just the Defendants motions and that this court not be mislead by the Defendants
malicious and fallacious arguments. The Defendants would like nothing more than to confuse

this court and refuse to address the obvious that has been addressed in the Plaintiffs complaints
and have never been alleged in any prior case:
1. The Plaintiffs claim in this current action that the Defendants committed extrinsic
fraud in prior litigation4 and have submitted evidence to substantiate these claims.
This is an allegation that has never been brought in any prior claim.
2. Defendant BANA acquired summary judgment in Echeverria I based on fraud.
3. Echeverria II was filed in Brevard County, Florida and removed to Federal Court by
Defendants BANA, MERS and Taylor, Bean & Whitaker (TB&W) who was an instate defendant. Plaintiffs filed a Motion to Remand and Judge John Antoon II
denied the Motion. Echeverria II should have been remanded back to state court.
Nonetheless, the new counts in Echeverria II were ignored and dismissed.
4. The Plaintiffs have never brought upon a claim against Urban or CGCG.
5. The Plaintiffs have never brought upon any cause of action of intentional
misrepresentation regarding Bank of Americas fictitious Office of the CEO and
President and how they relied on the misrepresentations of this fallacious office to
their detriment.
6. The Plaintiffs have never alleged in any prior claim that they were lied to by fake
Bank of America employees who were actually Urban and Carlisle & Gallagher
employees all along while holding fake titles which is actually a crime5 and while
handling their regulatory and governmental complaints.

See FRCP Rule 60. Relief from a Judgment or Order. This current action is an independent action that would
relieve the Plaintiffs from a prior judgment based on fraud.
5

See 18 U.S. Code 1342 - Fictitious name or address.

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7. The Plaintiffs were not aware of the criminal scheme perpetrated against them by all
named defendants until December 13, 20136 due to an investigation conducted by a
Bloomberg reporter. They were not aware of Urban or Carlisle & Gallaghers
involvement or even aware that the persons who they communicated with all along
were actually misrepresenting their identity and titles.
8. The Plaintiffs have never alleged in any prior claim that the Defendants collectively
were manipulating their account to: induce foreclosure; fool auditors; close their
active borrower file; manipulate the submission of personal and financial documents;
submitted their documents to locations whom they thought was Bank of America; had
their personal and financial documents purposely aged and discarded in an Urban
warehouse; posting calls that never happened and removing notes from calls; just to
name a few. This was clearly established by one of the many pieces of new
evidence7 submitted in this current action and has been never claimed before and
this evidence has never been filed before in any prior action.
9. The Plaintiffs were never aware and have never alleged in any prior claim that
Defendant BANA relied on Urban Reports to fraudulently deny their applications
and requests for HAMP.
10. The Plaintiffs have never alleged in any prior claim that the Defendants have
concealed a scheme involving their fictitious Office of the CEO and President to
communicate with the Plaintiffs attorneys.

6
7

In cases where a cause of action has been fraudulently concealed, the statute of limitations is tolled.
See Judicial Notice, Doc. 55.

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11. The Plaintiffs continued to receive fraudulent Office of the CEO and President
mailings during litigation and after litigation. These are other acts or violations
after any prior claim. On-going mail fraud and fraudulent misrepresentations.
12. The Plaintiffs have never alleged in any prior claim that Defendant BANA breached
their fiduciary duty with the Plaintiffs due to these new revelations and facts8.
13. The Plaintiffs have never alleged in any prior claim that they were continuously
harassed for a period of time until 2013 by one of Defendant BANAs contractors
SafeGuard by mail and with inspections9. This is another act or violation after any
prior claim.
14. The Plaintiffs have never alleged in any prior claim that they received numerous
communications and threats from Defendant BANA in 2013 and beyond stating that
their loan is NOW in Foreclosure10. These are damages, acts or violations after
any prior claim.
15. The Plaintiffs have never alleged in any prior claim that they received
communications in 2013 from JMA Adjustment Services, LLC, a third party
company working on behalf of Defendant Bank of America (BANA), to collect an
alleged debt and that this company, on behalf of BANA, offered the Plaintiffs another
fraudulent loan modification, a deed in lieu of foreclosure, a short sale, money to
move out of their home and gave them an inaccurate amount of the alleged debt11.
This is another act or violation after any prior claim.

See Sec. Amend. Comp. Doc. 60, 156-159.


See Sec. Amend. Comp. Doc. 60, 77.
10
See Sec. Amend. Comp. Doc. 60, 75.
11
See Sec. Amend. Comp. Doc. 60, 72- 75.
9

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16. The Plaintiffs have never alleged in any prior claim that they submitted a Fair Debt
Collection Practices Act letter to JMA Adjustment Services, LLC, to submit to the
so-called creditor Bank of America, N.A. This is another act or violation after any
prior claim.
17. The Plaintiffs have also made it clear in their complaints that the Defendant BANA
continued to violate the Fair Debt Collection Practices Act and Fair Credit
Reporting Act as recent as the year 2013. This is another act or violation after any
prior claim.
18. The Plaintiffs have brought upon new claims regarding breach of contract due to the
concealment of all parties handling the fraudulent contract and by placing them in an
alternate agreement (special forbearance) without their knowledge and consent that
was detrimental to them. This was also never alleged in any prior claim12.
19. The Interrogatories or the responses expected from such have never been raised in
any prior action by the Plaintiffs. The evidence that would be revealed would be
substantial and further convincing evidence for a jury and for this Court.
20. The Plaintiffs have submitted new relevant evidence to substantiate new claims, new
causes of actions and their allegations of fraud during litigation.
The Defendants expect this Court to continue to turn a blind eye at the facts and evidence
of this case. The Defendants also expect that this Court will only make their decision based on
whatever lie they type up on a motion to dismiss and ignore the Plaintiffs complaints, evidence
and judicial notices in violation of the Federal Rules of Civil Procedure.

12

See Sec. Amend. Comp. Doc. 60, 144-154.

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II.

THE DEFENDANTS MOTIVES FOR STAYING DISCOVERY IS OF A


MALICIOUS NATURE.
On October 28, 2014 Plaintiffs served their First Set of Interrogatories to Defendant Bank

of America, N.A. On October 29, 2014, Plaintiffs served their First Set of Interrogatories to
Defendant Urban Settlement Services and Carlisle & Gallagher.
As stated previously, Plaintiff Isabel Santamaria ironically received a call from BANAs
attorney Sahily Serradet on October 31, 2014, merely two days after all defendants have
collectively received their First Set of Interrogatories from the Plaintiffs. For quite some time,
the Plaintiffs had not heard from the Defendants. BANA refused to comply with the
requirements for their Initial Disclosures, would not reply to the Plaintiffs emails for weeks, and
all Defendants were dormant for quite some time13. All of a sudden, after the Report &
Recommendation plan failed, the conspiracy Defendants collectively had to hatch a new plan to
stop this discovery in its tracks in order to cease the Plaintiffs from receiving these revealing
responses to their interrogatories or alternatively, filing Motions to Compel and eventually
sanctions to receive this incriminating evidence further exposing their fraud. The Defendants do
NOT want to answer the Plaintiffs First Set of Interrogatories14 or comply with mandatory
Mediation.
This was not a Motion done in good faith, all the contrary. It is quite obvious that this
is a malicious ploy by the Defendants to confuse this Court and to avoid discovery and have this
case dismissed to once again to cover-up their ill-willed fraud and criminal activities that have
been perpetrated against the Plaintiffs for which the harm that has been caused remains unabated.
13

None of the Defendants filed expert witness reports, filed interrogatories, filed production of documents or any
other procedural discovery requests considering the fact that discovery started in August and was supposed to end
December 31, 2014. Very suspicious activity which would indicate inside information or influences from within
the court. Any reasonable person can observe that this is fraud and misconduct once again during litigation.
14

At the Courts request, the Plaintiffs may release the Interrogatories to the Court.

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This case by no means should be dismissed and this Court should not base their decisions
on the responses and motions filed by the criminal defendants in this case and carbon copy them
onto an Order or Recommendation as has been done in this current action by Magistrate Judge
Kelly, especially given the fact that this current action is also being tainted with fraud. According
to the Federal Rules of Civil Procedures, this Court is required to be impartial when evaluating
the Plaintiffs complaints, exhibits and judicial notices and not follow orders from criminal
parties such as the Defendants in this case.

Even though the Plaintiffs have provided sufficient case law throughout their Responses
and Oppositions and throughout this case in general thereby consistently opposing the
Defendants res judicata defense, in a worse case scenario, it remains to this Courts discretion
(and not to the discretion of a magistrate judge) to determine if there has been a manifest
injustice against the Plaintiffs that would allow this case to rightfully go to trial by jury.

Conclusion
The Plaintiffs did not agree to the Defendants Motion to Stay [Doc. 77] when they
conferred with Defendant BANAs counsel and were unrightfully denied the opportunity to file
an Opposition to said Motion in violation of their rights and in violation of this courts Local
Rule 3.01(b). For the record, Magistrate Judge Baker did not issue an appropriate Order
explaining why the Motion to Stay, which was an opposed motion, was granted.
WHEREFORE, the Plaintiffs respectfully request that this Court allow this case to
continue with discovery, VACATE magistrate judge Bakers Order [Doc. 79] and DENY the
Defendants Motion to Stay [Doc. 77] which was made in bad faith and with the intention to

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not only mislead this court with faulty arguments but also continue corrupting this current action
with fraud and by suppressing evidence thereby continuing their unabated misconduct during
litigation.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND


CORRECT TO THE BEST OF MY KNOWLEDGE.

Dated this 6th day of November 2014.

Respectfully submitted,

___________________________________
Abdiel Echeverria Plaintiff (pro se)

___________________________________
Isabel Santamaria Plaintiff (pro se)

499 Cellini Ave NE


Palm Bay, Florida 32907
(321) 676-4198
(321) 750-6697
Email: andyecorso@yahoo.com

CERTIFICATE OF SERVICE
I do hereby CERTIFY that a true and correct copy of the foregoing has been furnished to
Marc T. Parrino. Esq.; Kevin W. Cox, Esq.; Gary Soles; and Meghan D. Engle by:
(

) mail (

) fax (

) mail and fax (

) email

on this_______ day of_________________________, 20______.


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