Witness and Exhibit List

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FORT LAUDERDALE DIVISION

IN RE:

Samuel Fitzgerald Worrell,

Debtor.

_________________________________/

CASE NO.: 21-20622-PDR

CHAPTER 13

NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING’S SUPPLEMENTAL 

WITNESS AND EXHIBIT LIST

NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING (“Secured Creditor”), 

by and through its undersigned counsel, and files this Witness and Exhibit List for Trial, and states 

as follows:

WITNESS LIST

1. Representative of the Secured Creditor, Kenneth Davis, will testify as to the business records 

of the Secured Creditor and how those records are kept and maintained in the normal course 

of Secured Creditor’s business. Representative of Secured Creditor may also testify as to the 

fact that a default occurred and the amounts due and owing, and the representative will also 

testify as to Creditor’s servicing of Debtor’s loan and Creditor’s business records.

2. All witnesses listed by the Debtor.

3. Rebuttal and impeachment witnesses.

4. Samuel Fitzgerald Worrell aka Samuel H. Worrell

5. The Creditor reserves the right to call any witness listed and/or called by any other party and 

reserves the right to supplement this Witness List with additional witnesses as they become 

known or necessary, upon proper notice to the other parties.

EXHIBIT LIST

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1. Motion for Relief from Stay filed by Secured Creditor on January 19, 2022 (DE# 26).

2. Claim One (1) filed by NEWREZ LLC D/B/A SHELLPOINT MORTGAGE SERVICING 

filed on January 12, 2022.

3. Debtor’s Objection to Claim of 1-1 NewRez LLC d/b/a Shellpoint Mortgage Servicing 

filed on January 31, 2022 (DE# 30).

4. Secured Creditor’s Response to Objection to Claim filed on February 4, 2022 (DE# 36).

5. Secured Creditor’s Insurance Notices.

6. Secured Creditor’s Final Foreclosure Judgement dated February 21, 2018 (DE# 33)

7. Secured Creditor’s Loan Modification Denial Letter dated January 28, 2020.

8. All exhibits listed by Debtor.

9. All pleadings and attachments/exhibits thereto and all documents contained in court file 

for subject action.

10. All impeachment and rebuttal exhibits.

11. Any pleadings or documents filed in any bankruptcy proceeding involving any borrower(s) 

of the subject Note or Mortgage, any Plaintiff, or any owner of the subject property.

12. The Creditor reserves the right to utilize any exhibit listed by any other party and further 

reserves the right to supplement this Exhibit List with additional exhibits as they become 

known and/or necessary, upon proper notice to the other parties.

ROBERTSON, ANSCHUTZ, SCHNEID, CRANE 

& PARTNERS, PLLC 

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-997-6909

By: /s/April Harriott

April Harriott, Esquire

Florida Bar Number 37547

Email: aharriott@raslg.com

CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that on March 4, 2022, I caused to be electronically filed the 

foregoing with the Clerk of Court by using the CM/ECF system, and a true and correct copy has 

been served via CM/ECF or United States Mail to the following parties: 

Samuel Fitzgerald Worrell

7420 NW 41st Court

Lauderhill, FL 33319

Robin R Weiner

POB 559007

Fort Lauderdale, FL 33355

Office of the US Trustee

51 S.W. 1st Ave.

Suite 1204

Miami, FL 33130

ROBERTSON, ANSCHUTZ, SCHNEID, CRANE 

& PARTNERS, PLLC 

Attorney for Secured Creditor

6409 Congress Ave., Suite 100

Boca Raton, FL 33487

Telephone: 561-241-6901

Facsimile: 561-997-6909

By: /s/April Harriott

April Harriott, Esquire

Florida Bar Number 37547

Email: aharriott@raslg.com

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