On May 02, 2008 a
Answer 3123751 Comments: Answer|DEFT EARL K WOOD ANSWER TO PLTFS COMPLAINT
was filed
involving a dispute between
Zup Ii Llc,
Zup I Llc,
and
Earl K Wood,
Lisa Echeverri,
William Donegan,
for CA - Other
in the District Court of Orange County.
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IN THE CIRUIT COURT OF THE NINTH
JUDICIAL CIRCUIT, IN AND FOR
ORANGE COUNTY, FLORIDA
ZUP 1, LLC and ZUPII, LLC
Plainfiffs, CASENO.: 08-CA-10125
vs.
WILLIAM DONEGAN, as the Property /n T (r -y f—:5
c^
Appraiser of Orange County, Florida; EARL r~ = 3
C 3
K. WOOD, as the Tax Collector of Orange B^U "-.r;
—<
County, Florida; and LISA ECHEVERRI, as
•^'--V-
:;';o'
—rs- ^ - - v • r - .
the Executive Director ofthe Florida iTy-ZZ -. ro o-s
-Xoi
Department of Revenue, if ^
--. •
-0 -"tr-v!
o:i:;f-' 3 ••-.>-n
CP --'.o
Defendants, •~" .-^-
- ^ .
/ -:~ o>
ANSWER OF DEFENDANT, EARL K. WOOD, ORANGE
COUNTY TAX COLLECTOR TO PLAINTIFF'S COMPLAINT
COMES NOW, Earl K. Wood, Orange County Tax Collector, by and ttu-ough his
undersigned attomeys, and files this his Answer to Plaintiffs Complaint, as follows:
Allegations Common to All Counts
1. Admitted.
2. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
3. Admitted.
4. Admitted.
5. Admitted.
6. Admitted.
7. Admitted.
8. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
9. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
10. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
COUNT I - ZUP I. L.L.C.
11. Paragraphs 1 through 10 ofthis Answer are realleged and incorporated herein by
this reference.
12. Admitted.
13. Admitted.
14. Admitted.
15. Admitted.
16. Admitted.
17. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
18. Denied.
19. Denied.
20. Denied.
21. Denied.
22. Denied.
23. Admitted.
24. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
COUNT II - ZUP II. L.L.C.
25. Paragraphs 1 through 10 ofthis Answer are realleged and incorporated herein by
this reference.
26. Admitted.
27. Admitted.
28. Admitted.
29. Admitted.
30. Admitted.
31. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
32. Denied.
33. Denied.
34. Denied.
35. Denied.
36. Denied.
37. Admitted.
38. Defendant is without sufficient knowledge to either admit or deny the
allegations, and the same are therefore denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a tme and correct copy ofthe foregoing has been fumished by
U.S. Mail to James M. Spoonhour, 215 N. Eola Drive, Orlando, Florida 32801 and Marcos
Marchena, 976 Lake Baldwin Lane Suite 101, Orlando, Florida 32814 this (TIU day of May,
2008.
STEVEN R. BECHTEL
Florida Bar Number YlThlid
Mateer & Harbert, P.A.
225 East Robinson Street, Suite 600
Post Office Box 2854
Oriando, Florida 32802-2854
Telephone: (407)425-9044
Facsimile: (407)423-2016
Attomeys for Earl K. Wood, as Orange
County Tax Collector
H:\Bechlel SXOCTOZUP I, LLC and ZUP II, LLC Case No 08CA-r0125\ZUP answer.doc
Document Filed Date
May 21, 2008
Case Filing Date
May 02, 2008
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IN THE CIRUIT COURT OF THE NINTH JUDICIAL CIRCUIT, IN AND FOR ORANGE COUNTY, FLORIDA ZUP 1, LLC and ZUPII, LLC Plainfiffs, CASENO.: 08-CA-10125 vs. WILLIAM DONEGAN, as the Property /n T (r -y f—:5 c^ Appraiser of Orange County, Florida; EARL r~ = 3 C 3 K. WOOD, as the Tax Collector of Orange B^U "-.r; —< County, Florida; and LISA ECHEVERRI, as •^'--V- :;';o' —rs- ^ - - v • r - . the Executive Director ofthe Florida iTy-ZZ -. ro o-s -Xoi Department of Revenue, if ^ --. • -0 -"tr-v! o:i:;f-' 3 ••-.>-n CP --'.o Defendants, •~" .-^- - ^ . / -:~ o> ANSWER OF DEFENDANT, EARL K. WOOD, ORANGE COUNTY TAX COLLECTOR TO PLAINTIFF'S COMPLAINT COMES NOW, Earl K. Wood, Orange County Tax Collector, by and ttu-ough his undersigned attomeys, and files this his Answer to Plaintiffs Complaint, as follows: Allegations Common to All Counts 1. Admitted. 2. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. 9. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. 10. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. COUNT I - ZUP I. L.L.C. 11. Paragraphs 1 through 10 ofthis Answer are realleged and incorporated herein by this reference. 12. Admitted. 13. Admitted. 14. Admitted. 15. Admitted. 16. Admitted. 17. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. 18. Denied. 19. Denied. 20. Denied. 21. Denied. 22. Denied. 23. Admitted. 24. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. COUNT II - ZUP II. L.L.C. 25. Paragraphs 1 through 10 ofthis Answer are realleged and incorporated herein by this reference. 26. Admitted. 27. Admitted. 28. Admitted. 29. Admitted. 30. Admitted. 31. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. 32. Denied. 33. Denied. 34. Denied. 35. Denied. 36. Denied. 37. Admitted. 38. Defendant is without sufficient knowledge to either admit or deny the allegations, and the same are therefore denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a tme and correct copy ofthe foregoing has been fumished by U.S. Mail to James M. Spoonhour, 215 N. Eola Drive, Orlando, Florida 32801 and Marcos Marchena, 976 Lake Baldwin Lane Suite 101, Orlando, Florida 32814 this (TIU day of May, 2008. STEVEN R. BECHTEL Florida Bar Number YlThlid Mateer & Harbert, P.A. 225 East Robinson Street, Suite 600 Post Office Box 2854 Oriando, Florida 32802-2854 Telephone: (407)425-9044 Facsimile: (407)423-2016 Attomeys for Earl K. Wood, as Orange County Tax Collector H:\Bechlel SXOCTOZUP I, LLC and ZUP II, LLC Case No 08CA-r0125\ZUP answer.doc