673.3091, F.S.

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The 2010 Florida Statutes

Title XXXIX

COMMERCIAL

RELATIONS

Chapter 673UNIFORM COMMERCIAL CODE: NEGOTIABLE

INSTRUMENTS

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Chapter

673.3091 Enforcement of lost, destroyed, or stolen instrument.

(1) A person not in possession of an instrument is entitled to enforce the instrument if:

(a) The person seeking to enforce the instrument was entitled to enforce the instrument when loss of

possession occurred, or has directly or indirectly acquired ownership of the instrument from a person who was

entitled to enforce the instrument when loss of possession occurred;

(b) The loss of possess ion was not the result of a transfer by the person or a lawful seizure; and(c) The person cannot reasonably obtain possession of the instrument because the instrument was

destroyed, its whereabouts cannot be determined, or it is in the wrongful possession of an unknown person or

a person that cannot be found or is not amenable to service of process.

(2) A person seeking enforcement of an instrument under subsection (1) must prove the terms of the

instrument and the persons right to enforce the instrument. If that proof is made, s. 673.3081 applies to the

case as if the person seeking enforcement had produced the instrument. The court may not enter judgment in

favor of the person seeking enforcement unless it finds that the person required to pay the instrument is

adequately protected against loss that might occur by reason of a claim by another person to enforce the

instrument. Adequate protection may be provided by any reasonable means.

History.s. 2, ch. 92-82; s. 1, ch. 2004-3.

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IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT

IN AND FOR COLLIER COUNTY, FLORIDA

BANKUNITED,

non-successor in interestto [lawfully seized] BANKUNITED, FSB.,

purportedplaintiff(s),

vs.

DISPOSED CASE NO.: 09-6016-CA

JENNIFER FRANKLIN-PRESCOTT, et al.,purported defendants.

___________________________________________________________________/

NOTICE OF OBJECTION TO ANYHEARING&MAGISTRATEIN DISPOSED CASE

AND OF NON-CONSENT

NOTICE OF FRANKLIN-PRESCOTTS OBJECTION & NON-CONSENT

1. Jennifer Franklin-Prescott objects to any hearingand/or any magistrate in this disposed

action. Here, no hearingwas authorizedand/orlawfuland the notice a sham.

RECORD DISPOSITION

2. This action had been disposed on 08/12/2010.

ERRONEOUS NOTICE IN DISPOSED ACTION

3. On 02/12/2011, the Docket showed a notice of hearing which was amended. Here, the

notice did notpertain to Jennifer Franklin-Prescott and/or the disposed action but to Pedro

Luis Licourt, who is not any known party.

UNLAWFUL/UNAUTHORIZEDHEARINGIN DISPOSED ACTION

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4. Here, the erroneously alleged amended mtoin for summary judgment does not pertain to

this disposed action. Any hearing and/or any motion for summary disposition would be

improper, unauthorized, and/or unlawful.

NO FEBRUARYHEARINGAPPEARED ON THE DOCKET

5. Here, the 02/12/2011 Docket did not show any hearingand/orhearing date:

NO CONSENT& OBJECTION TO ANY MAGISTRATE (HEARING)

6. Previously and repeatedly, Franklin-Prescott had objected to any magistrate hearing.

Because of the record lack of any consent, a previous hearing had been cancelled in this

disposed action.

7. The record lackofconsentwas erroneously entered as non-contest:

VAGUE & AMBIGUOUS SHAM NOTICE

8. Here, the notice was vague, ambiguous, and unintelligent. A pleading is considered a sham

when it is inherently false and based on plain orconceded facts clearly known to be false

at the time the pleading was made. See Decker v. County of Volusia, 698 So. 2d 650, 651

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(Fla. 5th

DCA 1997); Destiny Constr. Co. v. Martin K. Eby Constr., 662 So. 2d 388, 390 (Fla.

5th

DCA 1995).

RECORD ABSENCE OFNOTEAND CONDITIONS PRECEDENT

9. Here, no genuine properly executed note had existed. Copies of a null and void

note/mortgage and/or hearsay were not admissible under the Code of Evidence. Here, there

were no witnesses and no notary had acknowledgedany authentic note/mortgage.

NON-BINDINGMODIFICATION AGREEMENT

10. BankUnited, FSB, and/or BankUnited knew and/or concealed that

8. The Modification will be legally binding upon the parties, only when it is signed

by Note Holder and each Borrower.11. Here, Walter Prescott did not sign the purported Loan Modification Agreement. See

12/21/2010 Notice of Filing of Original Loan Modification Agreement in disposed

(08/12/2010) action. Because here the alleged 09/05/2007 Modification Agreement was

notsigned by each Borrowerand/or Walter Prescott, it was not legally binding.

FAILURE TOPROVE TERMS

12. A person seeking enforcementof an instrument under UCC 3-309(a) mustprove the terms

of the instrument and the persons right to enforce the instrument. See UCC 3-309(b). Here,

plaintifffailed toprove any terms.

RECORD ABSENCE OFEXECUTION

13. Here, the alleged February 2006 note, mortgage, and/orsecurity instrumentdid not and could

not have possibly encumberedFranklin-Prescotts real property, because they were not

properly executed.

NOPROOFON FILE IN DISPOSED ACTION

14. Here, Franklin-Prescott had denied the authenticity ofsignatures on the purported note

and/ormortgage alluded to in this disposed case and demanded strictproofthereof, by clear

and convincing evidence, pursuant to 673.3081, Fla. Stat. (2008). See Adjustable Rate

Note, page 4 of 4, in 12/01/2010 and/or 11/01/2010 Notice of Filing of Original Note &

Original Mortgage.

15. Here in particular, there were, e.g., no notarial acknowledgment and no signature by

purported borrower Walter Prescott.

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16. The complaint and above Notice(s) of Filing established the purported note as null and

void. Furthermore, the non-genuine copies (prima facie hearsay) in the complaint and

Notices of Filing fatally conflicted.

PARTIES TO ALLEGED NOTE WERE CONFLICTING AND AMBIGUOUS

17. In this disposed action, the purported plaintiff did not assertany valid note and mortgage

assignment status in the complaint. A security could notpossibly follow a non-existent note.

18. Here, there was no assignee of any note. Here, no promissory note and no note assignment

were recorded. See Collier County Public Records. However, assignments must be recorded

to be valid against creditors and subsequent purchasers. 701.02, Fla. Stat. (2010). See also,

Glynn v. First Union Natl. Bank, 912 So. 2d 357, 358 (Fla. 4th

DCA 2005).

19. In this disposed action, the namedpartiesplaintiffs, and/orborrowers were conflicting and

ambiguous:

NO TRANSFER OF ALLEGEDINSTRUMENT

20. An instrument istransferred

when it isdelivered

by a person other than its issuer for thepurpose of giving to the person receiving delivery the right to enforce the instrument. See

UCC 3-203(a). If a transferor purports to transfer less than the entire instrument,

negotiation of the instrument does not occur. The transferee obtains no rights under this

Article and has only the rights of a partial assignee. See UCC 3-203(d). Here, the destroyed

and/or lost instrument could not have possibly been delivered and/or transferred, and the

case was disposed on 08/12/2010.

AUTOMATICALLY DISSOLVED LIS PENDENS

21. Here, the improper and unauthorized lis pendens was automatically dissolved upon the

disposition of foreclosure. See Rule 1.420(f), Fla. R. Civ. P. (2010). The validity of a notice

oflis pendens is one year from filing. 48.23(2), Fla. Stat. (2010).

22. In this disposed action, the purported plaintiff sought to re-establish the missingnote in

COUNT I (Reestablishment of Lost Instruments) of the complaint (see p. 2 of 8). Franklin-

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Prescott had filed her answer(s) and motions to dismiss and proven plaintiffs lack of

standing, which was one of the ultimate affirmative defenses. Here, the record reflected

thatplaintiffcould notpossiblyre-establish the note and that no authentic note couldpossibly

beproven under the Evidence Code.

FRAUD ON THE COURT & RECORD EVDENCE THEREOF

23. Here however, plaintiff(s), BankUnited and BankUnited, FSB, fraudulently asserted:

that all conditions to the institutions of this action have occurred, been performed or

excused

24. Prior to the 08/12/2010 disposition, plaintiff had failed to re-establish and could not have

possiblyre-established the destroyed and/orlostnote/mortgage. Here, the time and manner

of the loss/destruction had been uinknown. See UCC 3-309; 3-305.

02/12/11 DOCKET SHOWED FRAUD EVIDENCE &DEMAND IN DISPOSED ACTION

PREVIOUS NOTICE OF UNAVAILABILITY IN DISPOSED ACTION

25. Prescott who is in the Pacific had given her notice of unavailability. In this disposed action,

Prescott could not possibly be expected to appear under said entirely unreasonable

circumstances on such unintelligent, irrelevant, unauthorized, and short notice.

UNAUTHORIZED ATTORNEYS

26. Rose, Erin M. was the only attorney authorized in this disposed action.

Here unlawfully, various unknown attorneys appeared without any authority and falsely

pretended a hearing.

RECORD FRAUD ON THE COURT

27. This court knows about the fraud on the Court perpetrated by BankUnited & Albertelli Law:

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In this disposed action, any hearingand/or motion for summary disposition were unauthorized

and improper.

BANKUNITED HAD NO VALIDSECURITY INTEREST

28. In Florida, a security interest in a mortgage and/or the assignment of a mortgage must be

recorded in order to perfect the security interest in the mortgage. Here, no valid BankUnited

security interestexisted.

DEMAND OFLIS PENDENSBOND

29. Florida Statutes, section 48.23, governs the use of a lis pendens, and treats a lis pendens as

one of two types. Here, the purported invalid lis pendens was not founded on a duly recorded

instrument. Here, the purported promissory note was destroyed, lost, and/or transferred.

See Complaint. Furthermore here, there was the lawful seizure of bankrupt BankUnited

and/or an alleged transfer/sale. Here, the missing note/mortgage could not have possiblybeen reestablishedand/orenforced. 48.23(3), Fla. Stat. (1993) authorizes the trial court to

"control and discharge the notice of lis pendens as the court may grant and dissolve

injunctions." Here, Prescott appears to be entitled to a lis pendens bond.

30. Here, Prescott showed that the bond is necessary to protect her from irreparable harm after

the disposition. Here, the lis pendens was not based on a recorded genuine instrument. See

Feinstein v. Dolene, Inc., 455 So.2d 1126, 1128 (Fla. 4th DCA 1984).

31. Here, the note was missing and the lis pendens was unjustified. See Florida Communities

Hutchinson Island v. Arabia, 452 So.2d 1131, 1132 (Fla. 4th DCA 1984). Here, the null and

void lis pendens placed a cloud on the title that did not exist. See Andre Pirio Assocs. v.

Parkmount Properties, Inc., N.V., 453 So.2d 1184, 1186 (Fla. 2d DCA 1984).

32. In this disposed action, the bond is simply mandatory. See Porter Homes, Inc. v. Soda, 540

So.2d 195, 196 (Fla. 2d DCA 1989)(where a lis pendens is not founded upon a lawsuit

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involving a recorded instrument, section 48.23(3) "requires the posting of a bond."). See

Machado v. Foreign Trade, Inc., 537 So.2d 607, 607 n.1 (Fla. 3d DCA 1988); Munilla v.

Espinosa, 533 So.2d 895 (Fla. 3d DCA 1988).

CONTESTEDSIGNATUREON PURPORTEDNOTE

33. Here, the signature on the purported note was contested and not authentic. There was no

notarialacknowledgment. See evidence on file.

ALL PLEADINGS WERE SIGNED

34. Here, all of Franklin-Prescotts pleadings were signed (/s/ Jennifer Franklin-Prescott).

NOTICE OF INTERLOCUTORY APPEAL FROMHEARINGIN DISPOSED ACTION

35. Here, more than one hearingappeared on the Docket after said 08/12/2010 disposition and

Franklin-Prescott appeals from the unauthorized scheduling of hearings in this disposed

action.

AFFIRMATIVE DEFENSES PRIOR TO DISPOSITION

FIRST AFFIRMATIVE DEFENSE: FAILURE TO PRODUCE ORIGINAL NOTE

36. A person seeking enforcement of a lost, destroyed or stolen instrument must first prove

entitlementto enforce the instrument WHEN the loss of possession occurred, or has directly

or indirectly acquired ownership of the instrument from a person who was entitled to enforce

the instrument when loss of possession occurred. Further, he must prove the loss of

possession was not the result of a transfer by the person or a lawful seizure; and the person

cannot reasonably obtain possession of the instrument because the instrument was destroyed,

its whereabouts cannot be determined, or it is in the wrongful possession of an unknown

person or a person that cannot be found or is not amenable to service of process. 673.3091

Fla. Stat. (2009).

37. Here, Franklin-Prescott had denied the purported plaintiff has ever had possession of the

alleged note and/ormortgage. Plaintiffcould not establish foundation to show possession of

the note WHEN the loss of possession occurred. Plaintiff could not establish that plaintiff

lost possession of the note after it was transferred to the Plaintiff and that it could not

reasonably obtain possession thereof. Absent such proof in this disposed action, plaintiff

had been required by Florida Law to provide the original note and mortgage. Having failed

to provide the original note and mortgage at the time of filing, Plaintiff could notsue and/or

maintain this disposed action.

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38. Here, the Plaintiff could not prove the terms of the instrument and theplaintiff banks right to

enforce the alleged instrument. The court may not enter judgment in favor of the person

seeking enforcement unless it finds that the person required to pay the instrument is

adequately protected against loss that might occur by reason of a claim by another person to

enforce the instrument. Fla. Stat. 673.3091(2). In this disposed action, Franklin-Prescott

specifically had been denying all necessary terms of the note are provided in the attached

mortgage/note. Clearly, since the note is missing, necessary endorsements on the note are

missing; as such, essential terms and conditions precedent were not provided by theplaintiff.

UNCLEAN HANDS DEFENSE

39. Prescott had asserted and proven (another affirmative defense) that the plaintiff(s) had failed

to follow Florida law of negotiable instruments and including, e.g., obtaining necessary

signatures, acknowledgments, recordations, assignments, and/or endorsements on the

purported non-authentic promissory note and mortgage deceptively submitted to this Court

as alleged debtevidence. As such, theplaintiffcame to this court with unclean hands.

WHEREFORE Jennifer Franklin-Prescott respectfully demands

1. An Orderdetermining that the invalid lis pendens was not founded upon a duly recorded

authentic instrument therefore requiring a bond to prevent further irreparable harm following

the 08/12/2010 disposition;

2. An Orderdeclaring the purported plaintiff in this disposed action without any authority tosue,foreclose, and/ordemandanypaymentfrom Jennifer Franklin Prescott;

3. An Orderdeclaring any hearingunauthorized in this disposed action;

4. An Order declaring the prima facie sham motion and affidavits unlawful in this

previously disputed and disposed action;

5. An Orderdeclaring the purported note and/ormortgage unenforceable;

6. An Ordertaking judicial notice of the prima facie unenforceability of the unrecorded, un-

assignable, and unpaid mortgage (unpaid mortgage taxes);

7. An Orderdeclaring the purported plaintiff to be in violation of Fed.R.Civ.P. 1.510 in this

disposed and previously controverted action;

8. An Orderdeclaring the purported 2009 lis pendens invalid on its face and taking judicial

notice of the nullity of the lis pendens and unenforceable mortgage and/ornote;

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9. An Orderdeclaring said affidavits hearsay and lacking any legal and/or factual basis in

the absence of any authentic note and/ormortgage;

10. An Ordertaking judicial notice of the lack of anygenuine note, plaintiffs proven fraud

on the Court, opposition, opposition evidence, and case law as to this disposed case;

11. An Orderprohibiting Counsel and/or Jason M. Tharokh, Esq., who did not file any notice

from appearingin this disposed action.

Respectfully,

/s/Jennifer Franklin-Prescott, BankUnited foreclosure fraud victim

ATTACHMENTS

Docket, et al.

CERTIFICATE OF SERVICEI hereby certify that a true and correct copy of this NOTICE IN DISPOSED ACTION has been

delivered to BankUnited, Albertelli Law, P.O. Box 23028, Tampa, FL 33623, USA, the Clerk of

Court, and Hon. Hugh D. Hayes, Courthouse, Naples, FL 34112, USA, on February 12, 2011,

Pacific Time.

Respectfully,

/s/Jennifer Franklin Prescott, fraud victim

CC: Hon. Hugh D. Hayes (Disposition Judge),Albertelli Law

United States District Court

The Florida BarNew York Times

[email protected], [email protected],[email protected], [email protected],

[email protected], [email protected]

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Case Information Printer Friendly Version

Style: BANKUNITED vs FRANKLIN-PRESCOTT, JENNIFER

Uniform Case Number: 112009CA0060160001XX Filed: 07/09/2009

Clerks Case Number: 0906016CA

Court Type: CIRCUIT CIVIL Disposition Judge: HAYES, HUGH D

Case Type: MORTGAGE FOR ECLOSURES Disposed: 08/12/2010

Judge: HAYES, HUGH D Reopen Reason:

Case Status: DISPOSED Reopened:Next Court Date: Reopen Close:

Last Docket Date: 02/08/2011 Appealed:

Parties

Dockets

Events

Financials

Docket Type Judge Court Date Court Time

MOTION HEARING HAYES, HUGH D 12/06/2010 13:30

MOTION HEARING PEREZ-BENITOA, MAGISTRATE 09/02/2010 11:30

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Parties

Dockets

Events

Financials

2 of 2 pages. Entries per page: 60

Date Text All Entries

09/01/2010 OBJECTION TO MAGISTRATE

09/02/2010 CANCELLED

09/02/2010 MINUTES - HEARING SEE SCHEDULE MINUTES FOR DETAILS

09/02/2010 RECEIPT FROM DCAACKNOWLEDGMENT OF NEW CASE FILED W/DCA 8/18/10 2D10-4158

09/02/2010 ORDER BY DCAAPPELLANT SHALL WITHIN 15 DAYS SHALL FILE AN AMENDED APPEAL

09/02/2010 ORDER BY DCAAPPELLANT SHALL FORWARD FILING FEE OR ORDER OF INSOLVENCY WITTHIN40 DAYS

09/02/2010 ORDER BY DCA APPELLANT SHALL SHOW C AUSE WITHIN 15 DAYS

09/02/2010 NOTICE OF LACK OF JURISDICTION


09/02/2010 NOTICE NOTICE OF LACK OF JURISDICTION

09/02/2010 NOTICE

09/02/2010 MOTION FOR RECUSAL

09/02/2010 NOTIC E IN SUPPORT OF HUGH HAYES RECUSAL






09/07/2010 ORIGINAL SENATE STAFF RECORD EVIDENCE IN SUPPORT OF SANCTIONS

09/07/2010 NOTICE OF LACK OF JUSIDICTION

09/07/2010 REQUEST FOR JUDICIAL NOTICE

09/07/2010 NOTIC E OF AUTOMATIC DISSOLUTIO N OF LIS PENDENS

09/07/2010 REQUEST FOR JUDICIAL NOTICE




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09/14/2010 NOTIC E OF APPEAL AMENDED NOTICE OF APPEAL 2D10-4158

09/14/2010 COPY CORRESPONDENCE TO 2ND DCA W/ATTACHMENTS

09/15/2010 NOTIC E OF APPEAL AMENDED NOTICE OF APPEAL 2D10-4158

09/15/2010 COP Y AMENDED NOTIC E OF APPEAL TITLED TO 2ND DCA

09/15/2010 CORRESPONDENCE FROMAPPEAL CLERK TO DCA W/CERTIFIED COPY AMENDED NOTICE OF APPEAL2D10-4158

09/16/2010 CORRESPONDENCE FROMAPPEAL CLERK TO DCA W/CERTIFIED COPY AMENDED NOTICE OF 2ND AMENDEDNOTICE OF APPEAL

09/16/2010 DEMAND FOR FINAL ORDER

10/04/2010 ORDER BY DCATHIS APPEAL DISMISSED BECAUSE APPELLANT FAILED TO COMPLY WITH THISCOUR TS ORDER OF 8/31/10 R EQUIR ING A COPY OF ORDER APPEALED

10/25/2010 ORDER BY DCA THIS APPEAL IS DISMISSED

11/12/2010 NOTICE OF HEARING

11/12/2010 NOTIC E OF FILING AFFIDAVIT OF ATTORNEY FEES

11/12/2010 AFFIDAVIT AS TO ATTORNEYS FEES

12/02/2010 NOTIC E OF FILING ORIGINAL NOTE & ORIGINAL MORTGAGE

12/03/2010 MOTIONTO CANCEL UNAUTHORIZED HEARING IN DISPOSED ACTION MOTION FORJUDICIAL NOTICE / BY JENNIFER FRANKLIN-PRESCO

12/06/2010 CORRESPONDENCE FROM COUNSEL TO CLERK

12/06/2010 MOTION TO CANCEL HEARING

12/06/2010 OBJECTION TO& MOTION TO COMPEL & QUIET TITLE BY JENNIFER FRANKLIN-PRESCOT

12/06/2010 NO APPEARANCE BY THE PARTIES

12/06/2010 MINUTES - HEARING SEE SCHEDULE MINUTES FOR DETAILS

12/07/2010 NOTIC E OF CANCELLATION 12/06/10 @ 3:00 MOTION FOR SUMMARY JUDGMENT

12/08/2010 OBJECTION TO HEARING BY JENNIFER FRANKLIN PRESCOTT

12/08/2010 OBJECTION TOSTATUS OF DISPOSITION JUDGE & RECUSAL MOTION BY JENNIFER FRANKLINPRESCOTT

12/17/2010 NOTIC E OF FRAUD & LOSS BY JENNIFER FRANKLIN-PRESCOTT

12/17/2010 MOTIONTO CANCEL UNAUTHORIZED HEARING IN DISPOSED ACTION BY JENNIFER FRANKLIN

PRESCO12/20/2010 OBJECTION TO

(EMERGENCY) TO PURPORTED NOTE IN DISPOSED ACTION & UNNOTICED &UNAUTHORIZED HEARING IN FRAUD ON COUR T C ASE BASED ON DEFENDANT ET AL

12/22/2010 NOTIC E OF FILING ORIGINAL LOAN MODIFICATION AGREEMENT

01/04/2011 OBJECTION TO FRAUD ON THE COURT BY JENNIFER FRANKLIN-PRESCOTT

01/12/2011 NOTIC E OF DROPP ING PARTY JOHN DOE/JANE DOE

01/12/2011 MOTION FOR SUMMARY JUDGMENT

01/12/2011 AFFIDAVIT AS TO AMOUNTS DUE

01/12/2011 AFFIDAVIT AS TO ATTORNEYS FEES

02/01/2011 COPY

(FAX) NOTICE OF OPPOSITION & OPPOSITION EVIDENCE/FRAUD EVIDENCE &UNAVAILABILITY IN DISPOSED ACTION/NOTIFICATION OF COURT & CLERK ET AL

02/07/2011 NOTICEOF FRAUDULENT AFFIDAVITS BY JASON M TAROKH ESQ & OF UNLAWFUL/UNAUTHORIZED ACT BY ALBERTELLI LAW (UNSIGNED)

02/08/2011 NOTICE OF HEARING02/22/11 @10:00A.M., DEFENDANT'S MOTION TO DISMISS/MOTION TO ENJOIN

02/08/2011 AMENDED NOTIC E OF HEARING02/14/11 @3:30P.M. AMENDED MOTIONFOR SUMMARY JUDGMENT AND FORATTORNEY FEES AGAINST PEDRO LUIS LICOURT

02/08/2011 AMENDEDMTOIN FOR SUMMARY JUDGMENT AND FOR ATTORNEY FEES AGAINST PEDRO LUISLICOURT

02/09/2011 DEMANDOF FORENSIC REVIEW & AUDIT AND NOTICE OF FRAUDULENT AND/OR INACCURATEACCOUNTING IN DISPOSED ACTION



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Parties

Dockets

Events

Financials

Name Type DOB City, State, Zip

BANKUNITED PLAINTIFF

BANKUNITED FSB PLAINTIFF

PASKEWICZ, SERENA KAY ESQ PLAINTIFF'S ATTORNEY MIAMI, FL 33134

ROSE, ERIN M ESQ PLAINTIFF'S CO-COUNSEL TAMPA, FL 33623

FRANKLIN-PRESCOTT, JENNIFER DEFENDANT

PRESCOTT, WALTER DEFENDANT

DOE, JOHN DEFENDANT

DOE, MARY DEFENDANT

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