IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT

IN AND FOR LEE COUNTY, FLORIDA

CIVIL ACTION
US BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR GSMPS 2004-4,
Plaintiff,
CASE NO.: 36-2008-CA-055974
vs. DMSION:G

LARRY R. BRADSHAW, et ai,

Defendant(s).
------------------------~/
MOTION TO COMPEL

Plaintiff, US BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR GSMPS 2004-4, by and through
its undersigned counsel, files this Motion to Compel production of documents, answers to Interrogatories and
answers to Request for Admissions and as grounds therefore states as follows:
1. The Plaintiff propounded Interrogatories, Request for Production and Request for Admissions on
or about August 17,2009. Defendant had until September 22,2009, within which to respond to the above-
referenced discovery.
2. Plaintiff contacted counsel for the Defendant to make a good faith effort to obtain the requested
outstanding discovery responses and to date, Plaintiff has not received the requested responses from the Defendant.
WHEREFORE, the Plaintiff respectfully requests this Court enter an Order Compelling the Production of
Documents, answers to Interrogatories and answers to Request for Admissions referenced above as well as award
Plaintiff reasonable attorney's fees and costs as a result of this motion.
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail on this
--1- day of October, 2009, to all parties on the attached service list.

Florida Default Law Group, P.L.

P.O. Box 25018
Tampa, Florida 33622-5018
(813) 251-4766

FILE_NUMBER: F08086375 DOC_ID: M025016

lill~III~I~IIII~I~~~llil 111111111111~111~!~I~lil~II~~
 :\\-30
:B ~ (
r>. IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA
CIVIL ACTION
US BANK NATIONAL ASSOCIATION, AS TRUSTEE
FOR GSMPS 2004-4,
Plaintiff,
CASE NO.: 36-2008-CA-055974
vs. DIVISION: G

LARRY R. BRADSHAW, et aI,

Defendant(s).
--------------------~/ NOTICE OF HEARING

TO: All parties on the attached Service List

PLEASE TAKE NOTICE that the Motion to Compel will be called up for hearing before The Honorable

MICHAEL T. MCHUGH, Judge of the above-styled Court in Chambers in the LEE County Courthouse at 1700

Monroe St. Court Room 16, 4th floor, Fort Myers, FL 33901, on February 22,2010 at 11:OOAMEST, or as soon

thereafter as counsel may be heard.

PLEASE BE GOVERNED ACCORDfNGL Y. TIME RESERVED: FNE MINUTES.

Please be advised that the defendant is pro-se, therefore, this hearing did not require coordination. Please be

advised that Plaintiffs counsel attempted to coordinate the above hearing with Opposing Counsel's office and was

unsuccessful after three (3) attempts, therefore, this hearing was scheduled unilaterally.

I HEREBY CERTIFY that a true and '4°OPY of the foregoing has been furnished by U.S. Mail to all

parties listed on the attached service list on this day of January, 2010.

FILE_NUMBER: F08086375 DOC_ID: M025011

111111111111111111111111111111111111111111111111111111I 111111111111111111111111111111111111111111111
cc: Judge's Judicial Assistant
**See Americans with Disabilities Act**
If you are a person with a disability who needs any accommodation in order to participate in this
proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Ken Kellum,
Court Operations Manager whose office is located at Lee County Justice Center, 1700 Monroe Street, Fort
Myers, Florida 33901, and whose telephone number is (239) 533-1700; within two working days of your receipt
of this notice of sale; if you are hearing or voice impared, call1-SOO-955-S771 (TDD).
 ------
"

2/22/2010 4:23 PM Filed Lee County Clerk of Court

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND fOR

LEE COUNTY, FLORIDA . CIVIL ACTION

US Bank National Association, atf GSMPS

Plaintiff
vs
Bradshaw, Larry R etal
Defendant
------------------------------~/ Case No.: OB-CA-055974

MINUTES

Date: 2/22/10 Deputy Clerk: Sylvester

Judge: George Richards Court Reporter:

Attorney for Plaintiff: Greg Goetz ~ Present 0 Not Present

Attorney for Defendant: Larry R Bradshaw o Present IZI Not Present

Hearing Information
r>,
C8J Motion to Compel o Granted ~ Denied o Reserved
o Motion o Granted o Denied o Reserved
o Motion o Granted o Denied o Reserved
o Other: o Granted o Denied o Reserved
Notes:

Order to be prepared by:

~ Plaintiff's Attorney o Defendant's Attorney o Order signed in open court

o HEARING CANCELLED
 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR LEE COUNTY, FLORIDA
CIVIL ACTION

US BANK NA TIONAL ASSOCIATION, AS

TRUSTEE FOR GSMPS 2004-4,
Plaintiff,
CASE NO.: 36-2008-CA-055974
vs. DIVISION: G

LARRY R. BRADSHAW, et aI,

Defendant(s).
__________________________ 1

CORRECTED ORDER ON PLAINTIFF'S MOTION TO COMPEL

THIS CAUSE having come before the Court on February 22, 2010, on Plaintiffs Motion to Compel

and having reviewed the aforementioned documents and having heard the arguments of Plaintiffs Counsel and the

Defendant, and being otherwise fully advised in the premises, it is

ORDERED AND ADJUDGED as follows:

1. FPlaintiffs Motion to Compel is hereby GRANTED.

2. Defendant has twenty (20) days to respond to discovery.

DONE AND ORDERED day of

________ , 2010.

Circuit Court Judge

~~f~ll~'~
Conformed copies to:
Frances E. Johnson, Esquire
b~C.-r·~
Florida Default Law Group, P.L.
P.O. Box 25018
Tampa, Florida 33622-5018
All parties on the attached Service List

FILE_NUMBER: F08086375 DOCJD: M012913

111111111111111111111111111111111111111111111111111111I 111111111111111111111111111111111111111111111
 IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
LEE COUNTY, FLORIDA CIVIL ACTION

US Bank National Association, atf GSMPS ,

Plaintiff
vs
Bradshaw, Larry R etal
Defendant
________________________________ 1
Case No.: OB-CA-055974

MINUTES

Date: 2122110 Deputy Clerk: Sylvester

Judge: George Richards Court Reporter:

Attorney for Plaintiff. Greg Goetz I2J Present o Not Present

Attorney for Defendant: Larry R Bradshaw o Present I2J Not Present

Hearing Information

I2J Motion to Compel I2J Granted o Denied o Reserved

o Motion o Granted o Denied o Reserved
o Motion o Granted o Denied o Reserved
o Other: __ o Granted o Denied o Reserved
Notes:

Order to be prepared by:

I2J Plaintiff's Attorney o Defendant's Attorney o Order signed in open court

o HEARING CANCELLED
EILED
FEB 22 2010
..
0IAR1.lE GREEN, ClERK
ClRCUITICOlJNTY COURTS
BY D.C