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I am sorry to hear about this situation. I am including sample reply verbiage below:
COMES NOW the Defendant, JOHN DOE, a Florida resident, by and through its undersigned counsel, and answers the Plaintiff’s Complaint and alleges:
1. That Defendant, JOHN DOE, is without knowledge sufficient to admit or deny the allegations of Paragraphs 1-10 (or whatever the numbering is in the complaint) of Plaintiff’s Complaint and demands strict proof thereof.
2. The Defendant, JOHN DOE admits the allegations of Paragraph ____ of Plaintiff’s Complaint to the extent that Defendant, JOHN DOE, claims an interest in the subject property, but is with knowledge sufficient to admit or deny the allegations of priority contained therein and demands strict proof thereof.
3. That as an affirmative prayer for equitable relief from this Court, this Defendant prays that in the event of judicial sale of the subject property results in a surplus of funds after satisfying Plaintiff’s Judgment that such surplus be applied toward this Defendant’s claim for unpaid assessments, together with cost, interest, late fees, and reasonable attorney’s fees incurred in the collections, pursuant to Florida Statute and the Declaration for JOHN DOE, recorded in Plat Book ___at Page_____of the Public Records of Lucas County, Florida, as far as such surplus is able.
4. Any affirmative defenses that you may have will go here.
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