Filing # 58538067 E-Filed 07/03/2017 08:03:06 AM IN THE COUNTY COURT IN AND FOR BROWARD COUNTY, FLORIDA CACH, LLC Plaintiff/Judgment Creditor, vs. CASE NO.: COCE-13-016349 CHRIS LEONE Defendanv/Judgment Debtor, TYDON HOLDINGS, INC Gamishee. / PLAINTIFF’S SWORN OBJECTION TO DEFENDANT'S CLAIM OF EXEMPTION BEFORE ME this date appeared Ashley Moore, being personally known to me and having taken oath, deposes and says: 1. Affiant’s name is Ashley Moore, counsel for Plaintiff, CACH, LLC. I have personal knowledge of the facts stated herein. 2. Defendant has filed an affidavit for exemption alleging that they are head of household and that they provide more than one-half of the support for a child or other dependent. 3. As with all claims of exemption, the debtor has the burden of proving their entitlement to this exemption. Jn re Estridge, 7 Bankr. 873, 874 (Bankr. M.D.Fla. 1980; In re Parker, 147 B.R. 810, 812 (Bankr. M.D. Fla. 1992); Jn re Stevenson, 374 B.R. 891 (Bankr. M.D. Fla. 2007). 4, Defendant's Claim of Exemption fails to address the particular factors that would enable the Court or Plaintiff to determine whether Defendant is indeed the head of household, specifically the names and ages of the alleged dependent(s) and whether any other individuals reside at that home or contribute to the support of the home. 5. Defendant has failed to produce any documentation to support their claim as Head of Household. 6. Plaintiff is unable to determine Defendant’s entitlement to an exemption for “child support” due to their failure to provide said documentation to Plaintiff. #8 FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 7/3/2017 8:03:05 AM.##*CLAIM OF EXEMPTION AND REQUEST FOR HEARING from garnishment under the fotlo. | claim exemptios ing categories as checked: |, Head of family wages, (You must check a. or b, below.) 4. provide mor than oneal ofthe support fora child or ther dependent and have net earnings of $750 or less per week. x ©. {provide more than one-half of the suppor fora child or other dependeny, Have net eanings of mre than $750 per ee, bul have not ree in wring to hive my wages parished Social Security benefits. 3. Supplemental Security Income benefits 4. Public assistance (welfare). 3. Workers’ Compensation 6. Unemployment Compensation, 7. Neterans’ benefits. 8. Retirement or profit-sharing benefits or pension money, 9. Life insurance benefits or cash surrender value of life insurance policy or proceeds of ann eontract, 10, Disabitiy income benefits. 11. Prepaid College Trust Fund or Medical Savings Account X 208 Child Support | request a hearing to decide the validity of my claim, Notice of the hearing should be given to meat: rains BED SLY [2th v asf 1. CERTIFY UNDER OATH AND PENALTY OF PERIURY that @ copy of this CLAIM OF EXEMPTION AND REQUEST FOR HEARING has been furnished by (circle one) United States mail or hand delivery on (dare) (2 2-12, 0: insert names and addresses of Plainiff or Plaintiff's attorney andl of Garnishee or Garnishee 's attorney to whom this document was furnished) £387 SW j2tn ST Sa af an FC FPL ES I FURTHER CERTIFY UNDER OATH AND PENALTY OfBERSURY that the statements made in this request are true to the best of my knowledge and belief, = STATE OF FLORID) COUNTY OFF lms Beach Swag and subseribed before me this 25° day of Sune =» 20f% by Gen oy Notary Public/Deputy Clerk Personally known oR Produced identification Type of identification produced:7. Plaintiff timely contests Defendant’s Claim of Exemption, as required by F-S. 77.041, and denies Defendant is entitled to an exemption without the production of adequate supporting documentation. Cadle Co. v. Pegasus Ranch, Inc.,920 So. 2d 1276 (Fla. 4th DCA 2006). FURTHER AFFIANT SAYETH NAUGHT. : _ ISVS Ashley Moore State of: FLORIDA County of: PALM BEACH Appeared, Ashley Moore, personally known to me, and sworn to before me this June 29, 2017. ns 'SHANEEN MELENDEZ << %otary Publ - State of Foca i __bammiason @ FF 947550 \ $ { My Commission Expires:¢ “ane 1” Comm. Expires Ape 26,2020 [3S \.\ \SOSA ROTARY PUBLIC CERTIFICATE OF SERVICE 1 HEREBY CERTIFY that a tue and correct copy of the foregoing has been furnished via regular U.S. Mail to Defendant, CHRIS LEONE at 1387 SW 12th St, Boca Raton, FL 33486. Dated: June 29, 2017 Bryan Manno, Esq.-0414573 Ashley L. Moore, Tina D. Gayle, FEDERATED LAW GROUP, PLLC 887 Donald Ross Road Juno Beach, Florida 33408 Tel: (888) 362-7684 Fax: (800) 391-2178 Document service e-mail bmanno@federatedlaw.com