Answer: BANK OF AMERICA NA vs FLANAGAN JR DECEASED, THE UNKN et al

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                                ROBERT HOLLEY A/K/A ROBERT G. HOLLEY II A/K/A ROBERT G. HOLLEY, et al
1902 SW 2nd Ave
Okeechobee, FL 34974
Rgholley@hotmail.com
Defendant is self-represented


         IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT

                      IN AND FOR OKEECHOBEE COUNTY, FLORIDA



BANK OF AMERICA, N.A.,,                                 ANSWER

        Plaintiff,                                                                   pm,
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                                                        Civil No.: 472023CA000181    3           o>
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                                                        Judge:                                   mn
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ROBERT HOLLEY A/K/A ROBERT G.                                                        “3
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HOLLEY II A/K/A ROBERT G. HOLLEY, et                                                             om
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        Defendant(s).

       Defendant answers Plaintiff’s Complaint as follows.

                                RESPONSE TO ALLEGATIONS

        1.   Defendant denies the allegation in paragraph 1.

       2.    Defendant denies the allegation in paragraph 2.

       3.    Defendant denies the allegation in paragraph 3.

       Defendant denies each and every allegation in the Complaint that is not expressly

admitted herein.

       With respect to all paragraphs in which Plaintiff prays for damages or other relief,

Defendant denies that Plaintiff is entitled to such relief under law.

                                   AFFIRMATIVE DEFENSES



                                                  1      A self-service document from SoloSuit
Plaintiff’s claims are barred in whole or in part by the doctrines of laches, equitable

        estoppel, and unclean hands.

        Plaintiff’s claims are barred in whole or in part because of a failure to mitigate damages

        Plaintiff's claims are barred in whole or in part by the statute of limitations

        Plaintiff’s claims are barred in whole or in part due to the doctrine of accord and

        satisfaction.

        Defendant requests that Plaintiff perform an accounting and Provide Defendant with

        documentation that proves the amount that Defendant allegedly owes.

WHEREFORE,         Defendant requests the following relief:

   1    That   Plaintiff's Complaint    be dismissed with prejudice, and Plaintiff take nothing

        therefrom;

        The Defendant recover its reasonable fees and costs incurred in defending against this

        lawsuit;

        For such other and further relief as this Court may deem just and proper.



DATED     April 23, 2023


                                                              ist ROBERT HOLtE Y A/K/A
                                                              ROBERT6. HOLLEY IT
                                                              A/K/A ROBERT6. HOLLEY,
                                                              et al
                                                              ROBERT HOLLEY A/K/A ROBERT
                                                              G. HOLLEY II A/K/A ROBERT G.
                                                              HOLLEY, et al
                                                              Self-represented



                                                 2       A self-service document from SOloSuit
Original of the forgoing was caused to be filed via mail on April 23, 2023 to:
Okeechobee Clerk of Court
Circuit Civil
312 NW 3rd St.
Okeechobee FL 34972


Copy caused to be sent via mail on this day to:
Albertelli Law
P.O. Box 23028
Tampa FL 33623


                                                         vy ROBERT HOLLEY AVKA
                                                         ROBERT 6. HOLLEY IT
                                                         AVK/A ROBERT 6. HOLLEY,
                                                         et al
                                                         ROBERT HOLLEY A/K/A ROBERT
                                                         G. HOLLEY II A/K/A ROBERT G.
                                                         HOLLEY, et al
                                                         Self-represented




                                                  3    A self-service document from SoloSuit