JPMORGAN CHASE BANK NATIONAL ASSO -VS- ANNETTE M GANGALE RUSSELL

2. ANNETTE M. GANGALE RUSSELL AND STEVEN E. RUSSELL executed and delivered a Home Equity Line of Credit Agreement and Disclosure (the "Agreement") dated March 26, 2003 and ANNETTE M. GANGALE RUSSELL AND STEVEN E. RUSSELL executed and delivered an Equity Line of Credit Mortgage (the "Mortgage") dated March 26, 2003 securing payment of the amounts due under the Agreement. The Mortgage was recorded on May 16, 2003 , in Official Records Book at Page 1030 of the Public Records of SEMINOLE County, Florida, and mortgaged the real property ("Property") described therein. References made herein to "Borrower" refer to the individual(s) executing the Agreement; "Mortgagor" refers to those executing the Mortgage. True and correct copies of said Agreement and Mortgage are attached hereto as Exhibit "A" and Exhibit "B" respectively. The Agreement and Mortgage are from time to time hereafter referred to collectively as the "Home Equity Documents."

3. Plaintiff is the owner of the Home Equity Documents and is the record title holder pursuant to an assignment of mortgage attached hereto as Exhibit "C." Plaintiff has standing to enforce its rights and obligations under the Home Equity Documents including, without limitation, to initiate the instant action.

4. The Mortgage is superior in dignity to any prior or subsequent right, title, claim, lien or interest of the Defendants named herein or any person claiming by, through or under said Defendants since the institution of this suit.

5. Defendant(s), ALEXANDRIA EVE AYRAL is/are the current owner(s) of the property.

6. There has been a default in the payment of the amounts due under the Agreement and Mortgage in that the payment due for March 15, 2024 , and all subsequent payments have not been made.

7. Plaintiff has terminated the credit line account under the Agreement and hereby declares the full amount payable under the Agreement and Mortgage to be due and payable.

8. All conditions precedent to the filing of this action have been performed or have occurred.

9. Borrower(s), as obligor(s) under the Agreement, may be held personally liable for a deficiency, if any, unless Borrower(s) has/have discharged the subject debt in bankruptcy, in which event no deficiency is or will be sought.

10. There is now due and owing under the Home Equity Documents the principal sum of $54,889.96, together with all sums that may be due for interest, taxes, insurance, escrow advances, and/or fees for inspections, property preservations or other expenses incurred to protect the property, and expenses and costs of suit including but not limited to filing fees, recording fees, title search and examination fees, fees due for service of process and such other costs as may be allowed by this Court.

11. Plaintiff has and will incur reasonable attorneys' fees and costs and therefore, seeks to be awarded these fees as authorized by the subject loan documents and as authorized by law.

12. The Defendant(s), Unknown Person(s) in Possession of the Subject Property, has or claim to have an interest in the Property by reason of being in actual possession of same or by virtue of a tenancy at will, but the interest, if any, is subject and inferior to the lien of Plaintiff's Mortgage, or is otherwise terminable as provided by law.