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WALLSTREETESQ
WALLSTREETESQ, Attorney
Category: Bankruptcy Law
Satisfied Customers: 17223
Experience:  14 years exp., CH 7 AND 13 Bankruptcy cases, AFL-CIO UNION PLUS, UFT NYSID AND ALL MAJOR UNIONS
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Dear attorney, would you please glance this draft? I have

Customer Question

Dear attorney, would you please glance this draft? I have put parenthesis a reference of the plaintiff allegation...

IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

Hollywood Station Condominium Association, Inc., a CASE NO. 11031998
Florida Non Profit Corporation

Plaintiff,
v.

Nohemi Alarcon FKA Nohemi Lopez, and any Unknown Heirs, Devisees,
Grantees, Creditors and other Unknown persons or Unknown Spouses Claiming By,
Through and Under Nohemi Alarcon,

Defendant
_____________________________/


ANSWER TO THE COMPLAINT

The Defendant, Nohemi Alarcon (hereinafter Alarcon) hereby files her answers to Plaintiff’s Complaint as follows:

THE PARTIES

1. ALARCON lacks sufficient knowledge as to the allegations in paragraph two of the complaint. (Plaintiff is a FL non-for-profit corporation)
2. ALARCON admits the allegations in paragraph three of the complaint. (Defendant is sui juris)
3. ALARCON admits the allegations in paragraph four of the complaint. (Date when property was acquired)
4. ALARCON denies the allegations in paragraph five of the complaint. (Contractually and statutorily obligated to pay a share of the common expenses)

Wherefore, Defendant demands this court to dismiss with prejudice the above titled action. (Is this paragraph necessary?)

CREATION OF STATUTORY LIEN AND DEFAULT OF DEFENDANT(S)

5. ALARCON denies the allegations in paragraph six of the complaint. (Default and fail to pay)
6. ALARCON denies the allegations in paragraph seven of the complaint. (Delinquent amount shall accrue interest)
7. ALARCON lacks sufficient knowledge as to the allegations in paragraph eight of the complaint. (The Plaintiff filed a statutory claim of lien against Nohemi Lopez and subject real property on April 7, 2011.)
8. ALARCON admits the allegations in paragraph nine of the complaint. (Nohemi Lopez currently hold(s) possession of the property)

CONDITIONS PRECEDENT

9. ALARCON lacks sufficient knowledge as to the allegations in paragraph ten of the complaint. (Plaintiff has satisfied all conditions precedent to the commencement of proceedings to foreclose…)

SUPERIORITY OF PLAINTIFF’S CLAIMS

10. ALARCON lacks sufficient knowledge as to the allegations in paragraph eleven of the complaint. (The statutory claim of lien recorded by the plaintiff…creates a lien that is superior in dignity to the right, title, claim of lien or interest of Defendant(s)…)

ADDITIONAL AND UNKNOWN PARTIES

11. ALARCON denies the allegations in paragraph twelve of the complaint. (The claims asserted herein are superior to any right…any unknown spouses…)

RELIEF SOUGHT

12. ALARCON denies the allegations in paragraph thirteen of the complaint. (Plaintiff…entitlement to foreclose…)
13. ALARCON denies the allegations in paragraph fourteen of the complaint.(Plaintiff seeks judgment for damages against Defendant(s) Nohemi Lopez…).
14. ALARCON denies All the allegations of items a, b, c, d, e, f, g and h under paragraph fifteen of the complaint. (Plaintiff seeks…)

WHEREFORE, Defendant requests the Court to dismiss the Plaintiff’s Complaint.

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. mail to the Clerk of the Broward Court in Fort Lauderdale, Fl, and to Peter J. Guala, Esq., Association Law Group, P. L., P.O. Box 415848, Miami Beach, Florida 33141.
Submitted: 5 years ago.
Category: Bankruptcy Law
Expert:  WALLSTREETESQ replied 5 years ago.

WALLSTREETESQ :

Hello I am a licensed attorney here to help you with your question, please review my response and do not hesitate to ask for clarificati on

WALLSTREETESQ :

This is good, now make sure you send it to the plaintiff and file it with the Court clerk as soon as possible,

JACUSTOMER-5m44bhhp- :

and to do that i just need to send it via regular mail certified, right?

WALLSTREETESQ :

I would send it certified mail to the plaintiff, and file an original with the Court clerk

JACUSTOMER-5m44bhhp- :

filing the original means taking the document in person to court, right?

WALLSTREETESQ :

I would take in person, and submit a simple affidavit of service, stating when you mailed the answer to the Plaintiff,

JACUSTOMER-5m44bhhp- :

so, who should sign this affidavit...

WALLSTREETESQ :

you,

JACUSTOMER-5m44bhhp- :

and this affidavit needs to be signed by whom?

WALLSTREETESQ :

it is simple stating the date you mailed your answer

WALLSTREETESQ :

you only,

WALLSTREETESQ :

You give the affidavit to the court, just stating you mailed the answer to the Plaintiff

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