Answer: Leonard, Ernst Vs Leonard, Lynda

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                                Filing # 22362981 E-Filed 01/09/2015 11:11:10 AM

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR COLLIER COUNTY FLORIDA - CIVIL DIVISION

U.S.BANK NATIONAL ASSOCIATION,
Plaintiff,
v. CASE NO.: 14-CA-002797

ERNST LEONARD, LYNDA LEONARD,
COLLIER COUNTY, A POLITICAL
SUBDIVISION OF THE STATE OF FLORIDA,
FLORIDA HOUSING FINANCE
CORPORATION, UNKNOWN TENANT IN
POSSESSION 1, UNKNOWN TENANT IN
POSSESSION 2,

Defendants.
/

COLLIER COUNTY, FLORIDA’S VERIFIED ANSWER TO COMPLAINT

COMES NOW the Defendant COLLIE COUN TY, FLORIDA (hereinafter the
“COUNTY”), by and through the undersigned attorney, and presents its Verified Answer to the
Plaintiff's Complaint, and states to the Court as follows:

1. The County admits the allegations in paragraph 1 for jurisdictional purposes only.

2. The County admits the recording as set forth; however, it can neither admit nor
deny the remaining allegations in paragraph 2 due to insufficient knowledge thereof.

3. The County can neither admit nor deny the allegations in paragraph 3 due to

insufficient knowledge thereof.

4. The County can neither admit nor deny the allegations in paragraph 4 due to
insufficient knowledge thereof.
5. The County can neither admit nor deny the allegations in paragraph 5 due to

insufficient knowledge thereof.

[14-2799-CA/1143980/1] 1

Filed with Collier County Clerk of Courts6. The County cannot respond to the legal conclusion set forth in paragraph 6, and as

such a conclusion

Florida law.

is improper pleading; the law set forth by the Plaintiff is not representative of

7. The County admits the allegations in paragraph 7.

8. The County can neither admit nor deny the allegations in paragraph 8 due to

insufficient knowledge thereof.

9. The County can neither admit nor deny the allegations in paragraph 9 due to

insufficient knowledge thereof.

10. The County can neither admit nor deny the allegations in paragraph 10 due to

insufficient knowledge thereof.

11. | The County can neither admit nor deny the allegations in paragraph 11 due to

insufficient know]

ledge thereof.

12. The County can neither admit nor deny the allegations in paragraph 12 due to

insufficient knowl

ledge thereof.

13. | The County can neither admit nor deny the allegations in paragraph 13 due to

insufficient know]

ledge thereof.

14. | The County can neither admit nor deny the allegations in paragraph 14 due to

insufficient know

ledge thereof.

15. | The County admits it has a mortgage interest in the property and that its interest is

subordinate to the

Plaintiff's interest; however, the County states its interest is superior in dignity

to all other claimants herein.

WJHEREFORE, the County respectfully requests the Court:

[14-2799-CA/114

3980/1] 2A. Enter am Order requiring any excess and/or surplus funds remaining from the
proceeds of any sale ordered for the property, after the Plaintiff and all costs have been paid, to
be first paid over to the County towards the satisfaction of its lien.

B. Grant such other and further relief as the Court deems just in the circumstances.

COLLIER COUN TY, FLORIDA

KEVIN L. NOELL, ESQ.

Florida Bar No. 13811

Assistant County Attorney

3299 East Tamiami Trail, Suite 800
Naples, FL 34112-5749

Telephone: (239) 252-8400
Facsimile: (239) 252-6300

STATE OF FLORIDA )
JSS:
COUNTY OF COLLIER )
The undersigned, being a Notary Public for the State of Florida, hereby certifies that
KEVIN L. NOELL appeared before me this 5 day of penises 2015 and is

either personally known to me or produced the following identification:
personaly “nown eas ——

== , and after having first been swom stated that

he affixed his signature to the above and foregoing document, and that the statements contained

therein are true and correct to the best of his knowledge.

Apu. Bhd

> Notary Public Stele of Floriae NOTRY PUBLIC IN AND FOR THE STATE OF FLORIDA

Marian R Colti

4 ina enon Mtn ¥, Coees
OS @ [200s

Printed Name

Commission Expires

(14-2799-CA/1143980/1]

wCERTIFICATE OF SERVICE

The undersigned attorney hereby certifies that the above and foregoing Verified Answer
was electronically filed with the Florida Courts E-Filing Portal which will send a notice of
electronic filing to: Counsel of record on this am day of January, 2015.

A
po
KEVIN L. NOELL, ESQ.
Assistant County Attorney
E-mail Service to all addresses below:
kevinnoell@colliergov.net
thomas! olliergov.net
nancybradley@colliergov.net

[14-2799-CA/1143980/1] 4