• Foreclosure: assignee failed to conclusively refute borrower's affirmative defense that they were not given proper notice of default where notice of default sent to borrower did not specify type of default as required by terms of mortgage - Judy v. MSMC Venture, LLC, No. 2D11-1896 (Fla. 2d DCA Nov. 28, 2012) (reversing final judgment of foreclosure)
  • Foreclosure: court without authority to entertain motion to enforce purported loan modification after final foreclosure judgment; claim that lender orally agreed to modification at post-judgment hearing barred by applicable statute of frauds Vargas v. Deutsche Bank Nat’l Trust Co., No. 3D11-554 (Fla. 3d DCA Nov. 28, 2012) (affirming order adopting report and recommendation)