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Appellant Mary Jean Ziska Reply Brief ( 2DCA case) from wrongful foreclosure case based on "void ab initio" mortgage where the signature of Option One Mortgage was executed ( November 2, 2006) clearly after an "Order Determining Limited Incapacity" with the "right to contract" removed ( January 03, 2006). The "Order Determining Limited Incapacity" was signed by Judge Hugh Hayes on January 3, 2006.
Appellant Mary Jean Ziska Reply Brief ( 2DCA case) from wrongful foreclosure case based on "void ab initio" mortgage where the signature of Option One Mortgage was executed ( November 2, 2006) clearly after an "Order Determining Limited Incapacity" with the "right to contract" removed ( January 03, 2006). The "Order Determining Limited Incapacity" was signed by Judge Hugh Hayes on January 3, 2006.
Appellant Mary Jean Ziska Reply Brief ( 2DCA case) from wrongful foreclosure case based on "void ab initio" mortgage where the signature of Option One Mortgage was executed ( November 2, 2006) clearly after an "Order Determining Limited Incapacity" with the "right to contract" removed ( January 03, 2006). The "Order Determining Limited Incapacity" was signed by Judge Hugh Hayes on January 3, 2006.
Filing # 77393925 E-Filed 09/04/2018 02:44:59 PM
UNITED STATES DISTRICT COURT
THE SECOND DISTRICT COURT OF APPEAL
CASE NO. (2D17-1909)
MARY JEAN ZISKA
APPELLANT
y.
215 MORTGAGE
APPELLEE
ON APPEAL FROM THE 20" JUDICIAL CIRCUIT COURT OF
COLLIER COUNTY FLORIDA USA CASE: (11-2015-CA-001170-0001-XX)
RECEIVED, 7/7/2018 11:55 PM, Clerk, Second District Court of Appeal
APPELLANT MARY JEAN ZISKA’S REPLY BRIEF
JULY 07, 2018
MARY JEAN ZISKA
PRO- SE APPELLANT
A 5632 WHISPER WOOD BLVD. UNIT 1601
NAPLES, FLORIDA 34110
RESCUEMARYJEANZISKACONDO@GMAIL.COM
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 09/05/2018 11:39:21 AM.ORAL ARGUMENT OPPOSITION
*Motion of 2 pages titled: “APPELLANT MARY JEAN ZISKA’S
RESPONSE MOTION IN OPPOSITION TO APPELLEE’S REQUEST
FOR ORAL ARGUMENT: REQUESTING IN MOTION THE SECOND
DISTRICT COURT OF APPEAL DENY APPELLEE’S REQUEST FOR
ORAL ARGUMENT; TERMINATE AND DISPENSE WITH ANY FORM
OF ORAL ARGUMENT IN APPEAL CASE 2D17-1909”_ Submitted to lower
tribunal civil action number: (11-2015-CA-001170-0001-XX) ON 04/03/2018 E-
FILING # 70132860 @ 4: 33:58AM.
*Motion of 72 Pages titled: “APPELLANT MARY JEAN ZISKA’S
RESPONSE MOTION IN OPPOSITION TO APPELLEE’S REQUEST
FOR ORAL ARGUMENT; REQUESTING IN MOTION THE SECOND
DISTRICT COURT OF APPEAL DENY APPELLEE’S REQUEST FOR
ORAL ARGUMENT; TERMINATE AND DISPENSE WITH ANY FORM
OF ORAL ARGUMENT IN APPEAL CASE 2D17-1909 Submitted to the
Second District Court of Appeal on: 04/03/2018 E-Filing received: 4:19AM,
Clerk, Second District court of Appeal Case ( 2D17-1909).
APPELLANT MARY JEAN ZISKA’S REPLY BRIEF SUBMITTED TO
THE SECOND DISTRICT COURT OF APPEAL FOR CASE 2D17-1909.SUBMITTED ON July 7, 2018, as per the Rules of Appellate Procedure 9.210
(BRIEFS Pages124-127) “CONTENTS OF REPLY BRIEF” Rule 9.210(d):
“The reply brief shall contain argument in Response and rebuttal to argument
presented in the answer brief. A table of contents, a table of citations, a certificate
of service, and for computer-generated briefs, a certificate of compliance shall be
included int eh same manner as the initial brief.” 9.210 (5) (B): Except as
provided in subdivision (a)(5)(C) and (a)(5)(D) of this rule, the initial and answer
briefs shall not exceed 50 pages and the reply brief shall not exceed 15 pages.
Also submitted on July 7, 2018, as per the Rules of Appellate Procedure 9.220:
(APPENDIX Pages 131-132).
(a) Purpose. The purpose of an appendix is to permit the parties to prepare and
transmit copies of those portions of the record deemed necessary to an
understanding of the issues presented. It may be served with any petition, brief,
motion, response, or reply but shall be served as otherwise required by these rules.
In any proceeding in which an appendix is required, if the court finds that the
appendix is incomplete, it shall direct a party to supply the omitted parts of the
appendix. No proceeding shall be determined until an opportunity to supplement
the appendix has been given.
(b) Contents. The appendix shall contain a coversheet, an index, a certificate, and
a conformed copy of the opinion or order to be reviewed and may contain any
Docket 326 o FAppeal Case 2D17-1909. Appendix Exhibit (X) - Total 63 Pages. Transcript Exhibits Objection To The Foreclosure Sale Hearing Februay 17 2017 Docket 210.
Docket 327. Appendix Exhibit (Y) - Total of 59 Pgs. May 03 2017. Transcript Exhibits From Reconsideration and Releif From Objection To The Foreclosure Sale Hearing. Docket in Lower Tribunal 256.
Docket 322 Appeal Case 2D17-1909. Appendix Exhibit S. Total of 39 Pages. Evidence Vaulted Admitted Docket 113. Trascript Foreclosure Hearing 149. Letters and Orders Apppointing Successor Interim Guardian. Record 374 375 376
Docket 323. Appeal Case 2D17 1909. Total 41 Pages. Appendix Exhibit T. Petition to Compel Interim Guardian to Return Funds Cease Ad Desist From Diverting Funds and to Compel Guardian to Act Within Court Ordered Autorization.
Docket 324. Appeal Case 2D17 1909. Appendix Exhibit U. 35 Total Pages. Order of Restoration of Rights and Dismissal of Guardianship Proceedings .May 03 2017. Dockets in GA Case Found On 250 251 252.
Docket 318 Appendix Exhibit J. Total of 46 Pages. Court Appointed Guardianship Accountability and Senior Protection Act. 114th Congress (2015-2016) - Total 46 Pages
Docket 325 of Appeal Case 2D17 1909. Appendix Exhibit W. Transcript Exhibits for Foreclosure Hearing 21st Mortgage v. Mary Jean Ziska on August 05, 2016 Docket Number 149 for Case 11 2015 CA 001170 0001-XX