Document for Flatline Concrete & Customs LLC v. Seyed Amir Sadeghi, PURDUE FEDERAL CREDIT UNION, REGIONAL DEVELOPMENT COMPANYet al

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                                Filed: 10/4/2022 1:46 PM
                                                                                           Clerk
                                                                   Tippecanoe County, Indiana




STATE OF INDIANA    )     IN THE TIPPECANOE SUPERIOR COURT 2
                    ) SS:
COUNTY OF TIPPECANOE)     LAFAYETTE, INDIANA

FLATLINE CONCRETE & CUSTOMS, LLC,

             Plaintiff,

       v.                               Case Number: 79D02-2208-PL-000075

SEYED AMIR SADEGHI, ET AL,

             Defendants.

       ANSWER OF DEFENDANT UNITED STATES OF AMERICA

            Comes now United States of America, defendant herein, by its

counsel Clifford D. Johnson, United States Attorney for the Northern

District of Indiana, through Brian Irvin, Assistant United States

Attorney, for and on behalf of its agency the Small Business

Administration, and states for its Answer to plaintiff’s Complaint to

Foreclose Mechanic’s Lien and for Other Relief:

     1.     That the defendant United States of America believes that the

statements of the plaintiff contained in rhetorical paragraphs 5 and 6 of

plaintiff's complaint are correct insofar as it states an interest of the

United States of America in the property in question. The government

further states as follows:

            That defendant, Seyed Amir Sadeghi, is indebted
            to the United States of America in the amount of
            $466,398.45 plus additional interest as to its SBA
             Loan as of October 20, 2022. Attached hereto are
             a Note and Mortgage.

     2.      That the defendant United States of America is without

information as to the truth or falsity of the material allegations contained

in rhetorical paragraphs 1 through 4, and 7 through 41 of plaintiff's

complaint.

     WHEREFORE, defendant, United States of America, prays that in

any judgment rendered in this cause, the lien of the United States be set

out and recognized in any decree of this court and that in the event of the

sale of said property pursuant to any order of this court, said liens will

attach to the proceeds of the sale thereof, and for all other proper and

necessary relief in the premises.

                                    Respectfully submitted,

                                    CLIFFORD D. JOHNSON
                                    UNITED STATES ATTORNEY

                             By:    /s/ Brian Irvin
                                    BRIAN IRVIN
                                    Assistant United States Attorney
                                    United States Attorney’s Office
                                    Northern District of Indiana
                                    5400 Federal Plaza, Suite 1500
                                    Hammond, Indiana 46320
                                    Tel: (219) 937-5500
                                    Fax: (219) 852-2770
                                    Brian.Irvin@usdoj.gov

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                         CERTIFICATE OF SERVICE

      I hereby certify that on October 4, 2022, Assistant United States

Attorney Brian Irvin electronically filed the foregoing ANSWER OF

DEFENDANT UNITED STATES OF AMERICA using the Odyssey E-Filing

system, which sent notification of such filing to the following:

Kaylin O. Cook
Rachel S. Bir
Cecelia N. Harper
Jill A. Dunn
M. Michael Stephenson
Jeremy D. Musgrave
Steven Kyle Dietrich



                                     /s/ Elizabeth B. Schaefer
                                     ELIZABETH B. SCHAEFER
                                     Legal Assistant


OFFICE OF:

United States Attorney
5400 Federal Plaza, Suite 1500
Hammond, Indiana 46320
Tel: (219) 937-5500
Fax: (219) 852-2770




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