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Filing # 185861854 E-Filed 11/09/2023 03:44:36 PM
IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT
IN AND FOR HIGHLANDS COUNTY, FLORIDA
CASE NO.
FLORIDA DREAM LANDS, LLC., a Florida limited
liability company,
Plaintiff,
VS.
EDWARD R. HOGAN, if alive and if not his unknown
spouse, heirs, devisees, grantees, creditors, or other parties
claiming by, through, under or against EDWARD R. HOGAN;
ROSE E. HOGAN, if alive and if not her unknown spouse,
heirs, devisees, grantees, creditors, or other parties claiming
by, through, under or against ROSE E. HOGAN; EDWIN P.
DEFREYTAS, if alive and if not his unknown spouse, heirs,
devisees, grantees, creditors, or other parties claiming by,
through, under or against EDWIN P. DEFREYTAS; ELNA M.
DEFREYTAS, if alive and if not her unknown spouse, heirs,
devisees, grantees, creditors, or other parties claiming by,
through, under or against ELNA M. DEFREYTAS; ALL
PERSONS UNKNOWN, CLAIMING ANY LEGAL OR
EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST
IN THE PROPERTY DESCRIBED IN THE COMPLAINT
ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON
PLAINTIFF’S TITLE THERETO, INCLUSIVE,
Defendant(s).
/
COMPLAINT TO QUIET TITLE
Plaintiff, FLORIDA DREAM LANDS, LLC., a Florida limited liability company,
(hereinafter, the “Plaintiff” or “FL DREAM”), by and through their undersigned counsel, files this
Complaint to quiet title against the Defendants, EDWARD R. HOGAN, if alive and if not his
unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under
or against EDWARD R. HOGAN, (“E HOGAN”); ROSE E. HOGAN, if alive and if not her
unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under
1
Electronically Filed Highlands cose iyhey GARXNEY
yey erego3pi4ge PM
or against ROSE E. HOGAN, (“R HOGAN”); EDWIN P. DEFREYTAS, if alive and if not his
unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under
or against EDWIN P. DEFREYTAS, (“ED DEFREYTAS”); ELNA M. DEFREYTAS, if alive
and if not her unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by,
through, under or against ELNA M. DEFREYTAS, (“E DEFREYTAS”); and ALL PERSONS
UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN,
OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO
PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE THERETO, INCLUSIVE,
(collectively, the “Defendants”), and alleges as follows:
COUNTI
1 This is an action in which FL DREAM seeks to quiet its title to certain real property
situated in Highlands County, Florida, filed pursuant to F.S. §65.081. Alternatively, in the
event that the tax deed in the Plaintiffs chain of title are determined invalid as to the
Defendants, EHOGAN, and R HOGAN, this is also an action to foreclose a statutory lien
for such invalidated tax deed pursuant to the provisions of F.S. §197.602.
FL DREAM does not know the true names of Defendant(s), ALL PERSONS
UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE,
LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT
ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE
THERETO, INCLUSIVE.
FL DREAM is the owner in fee simple of the following described land in Highlands
County, Florida:
2
Myles A. Hoover P.a.
A. LEGAL DESCRIPTION: LOTS 19 AND 20, BLOCK 11, AVON PARK
LAKES, RED HILL FARMS ADDITION, UNIT F, ACCORDING TO
THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 5, PAGES 49
AND 55, OF THE PUBLIC RECORDS OF HIGHLANDS COUNTY,
FLORIDA.
B. PARCEL #: C-01-33-28-070-0110-0190
C. ADDRESS: 2708 W KENOSHA RD, AVON PARK, FL 33825
4 None of the land constituting the subject matter of this suit is held by the U.S.
Government or by the State of Florida and said Governmental bodies have relinquished or
conveyed all of their rights, title or interest in and to said land and each and every parcel
thereof, by patent, statute or other appropriate actions, as shown by entry in the Public
Records of Highlands County, Florida.
5 DERAIGNMENT OF PLAINTIFFS’ TITLE: FL DREAM deraigns its title to the
subject property as follows: (all recording data in this complaint refers to the public records
of Highlands County, Florida, unless otherwise specified).
A The Clerk of Circuit Court of Highlands County, Florida conveyed the
above described property to the Plaintiff, FL DREAM, by Tax Deed dated
November 1, 2023, and recorded on November 2, 2023, at Official Records
Book 3007, Page 1128, of the Public Records of Highlands County, Florida. A
copy of the Tax Deed is attached hereto and incorporated herein as Exhibit “A”.
6. CLAIMS OF DEFENDANTS: The claims of Defendants, E HOGAN, and R
HOGAN, which casts a cloud or suspicion upon the title of FL DREAM are as follows:
3
Myles A. Hoover P.a.
A Said land was conveyed to the Defendants, EHOGAN, and R HOGAN, by
a Trustee’s Deed dated September 18, 1962, and executed by Hue E. Nunnallee,
as the grantor. The Trustee’s Deed was recorded on November 7, 1962, at
Official Records Book 159, Pages 159-160, of the Public Records of Highlands
County, Florida. A copy of the Trustee’s Deed is attached hereto and
incorporated herein as Exhibit “B”.
7
Any and all claims, rights, title or interest of the Defendants, E HOGAN, and R
HOGAN, to the real property described above have been extinguished by the tax deed
described herein, and FL DREAM is the true record title owner to the real property and the
legal and equitable owner in fee simple, and is entitled to have its title to the real property
quieted and confirmed by the Court under provision of F.S. §65.081.
Pleading in the alternative, FL DREAM requests that if this court determines that
the tax deed title issued to FL DREAM is void as to the Defendants, E HOGAN, and R
HOGAN, that the Court determines in its final judgment that FL DREAM holds a good
and valid lien on the subject real property for the amount of money paid by FL DREAM
for the tax deed together with interests thereon at 12% per annum from the purchase,
November 1, 2023, and the costs of this action, including attorney’s fees.
WHEREFORE, FL DREAM, being without remedy save in a Court of equity prays
as follows:
A That upon final hearing, the fee simple title to the above-described property be
adjudged to be in FL DREAM.
B That the Defendants, EHOGAN, and R HOGAN, be required to set forth the nature
of their claim in and to the above-described real property, and that all adverse claims by
4
Myles A. Hoover P.a.
any Defendants or those claiming by, through, under or against any Defendant, be
determined by a judgment of this court to be null and void as against FL DREAM.
That all rights, title and interest of any Defendants and those parties claiming by,
through, under or against any Defendant be forever quieted and confirmed in FL DREAM.
That in the event the tax deed title of FL DREAM be invalidated, FL DREAM’s
statutory lien for the amount paid for the tax deed together with interest from the date the
tax deed was purchased, costs, and attorney’s fees be foreclosed and that the subject real
property be sold by the Clerk of Courts to satisfy said lien.
COUNT I
This is an action in which FL DREAM seeks to quiet its title to certain real property
situated in Highlands County, Florida, filed pursuant to F.S. §65.081. Alternatively, in the
event that the tax deed in the Plaintiffs chain of title are determined invalid as to the
Defendants, ED DEFREYTAS, and E DEFREYTAS, this is also an action to foreclose a
statutory lien for such invalidated tax deed pursuant to the provisions of F.S. §197.602.
10. FL DREAM does not know the true names of Defendant(s), ALL PERSONS
UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE,
LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT
ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE
THERETO, INCLUSIVE.
11 FL DREAM is the owner in fee simple of the following described land in Highlands
County, Florida:
A. LEGAL DESCRIPTION: LOTS 16 AND 17, BLOCK 29, HIGHLANDS
PARK ESTATES, SECTION R, ACCORDING TO THE PLAT
5
Myles A. Hoover P.a.
THEREOF, AS RECORDED IN PLAT BOOK 5, PAGE 17, OF THE
PUBLIC RECORDS OF HIGHLANDS COUNTY, FLORIDA.
B PARCEL #: C-20-36-30-150-0290-0160
Cc ADDRESS: 1225 BRADLEY AVE, LAKE PLACID, FL 33852
12 None of the land constituting the subject matter of this suit is held by the U.S.
Government or by the State of Florida and said Governmental bodies have relinquished or
conveyed all of their rights, title or interest in and to said land and each and every parcel
thereof, by patent, statute or other appropriate actions, as shown by entry in the Public
Records of Highlands County, Florida.
13 DERAIGNMENT OF PLAINTIFFS’ TITLE: FL DREAM deraigns its title to the
subject property as follows: (all recording data in this complaint refers to the public records
of Highlands County, Florida, unless otherwise specified).
A The Clerk of Circuit Court of Highlands County, Florida conveyed the
above described property to the Plaintiff, FL DREAM, by Tax Deed dated
November 1, 2023, and recorded on November 2, 2023, at Official Records
Book 3007, Page 1129, of the Public Records of Highlands County, Florida. A
copy of the Tax Deed is attached hereto and incorporated herein as Exhibit “C”.
14. CLAIMS OF DEFENDANTS: The claims of Defendants, ED DEFREYTAS, and
E DEFREYTAS, which casts a cloud or suspicion upon the title of FL DREAM are as
follows:
A Said land was conveyed to the Defendants, ED DEFREYTAS, and E
DEFREYTAS, by a Warranty Deed dated September 21, 1960, and executed
by Highlands Downs, INC, as the grantor. The Warranty Deed was recorded on
6
Myles A. Hoover P.a.
October 21, 1960, at Official Records Book 106, Page 403, of the Public
Records of Highlands County, Florida. A copy of the Warranty Deed is attached
hereto and incorporated herein as Exhibit “D”.
15 Any and all claims, rights, title or interest of the Defendants, ED DEFREYTAS,
and E DEFREYTAS, to the real property described above have been extinguished by the
tax deed described herein, and FL DREAM is the true record title owner to the real property
and the legal and equitable owner in fee simple, and is entitled to have its title to the real
property quieted and confirmed by the Court under provision of F.S. §65.081.
16 Pleading in the alternative, FL DREAM requests that if this court determines that
the tax deed title issued to FL DREAM is void as to the Defendants, ED DEFREYTAS,
and E DEFREYTAS, that the Court determines in its final judgment that FL DREAM holds
a good and valid lien on the subject real property for the amount of money paid by FL
DREAM for the tax deed together with interests thereon at 12% per annum from the
purchase, November 1, 2023, and the costs of this action, including attorney’s fees.
WHEREFORE, FL DREAM, being without remedy save in a Court of equity prays
as follows:
A That upon final hearing, the fee simple title to the above-described property be
adjudged to be in FL DREAM.
That the Defendants, ED DEFREYTAS, and E DEFREYTAS, be required to set
forth the nature of their claim in and to the above-described real property, and that all
adverse claims by any Defendants or those claiming by, through, under or against any
Defendant, be determined by a judgment of this court to be null and void as against FL
DREAM.
7
Myles A. Hoover P.a.
Cc That all rights, title and interest of any Defendants and those parties claiming by,
through, under or against any Defendant be forever quieted and confirmed in FL DREAM.
That in the event the tax deed title of FL DREAM be invalidated, FL DREAM’s
statutory lien for the amount paid for the tax deed together with interest from the date the
tax deed was purchased, costs, and attorney’s fees be foreclosed and that the subject real
property be sold by the Clerk of Courts to satisfy said lien.
Respectfully submitted,
MYLES A. HOOVER P.A.
11 Island Ave, # 406
Miami Beach, FL 33139
Telephone 786.312.0803
By:4/Myles A. Hoover
MYLES A. HOOVER (FBN 1026217)
Email: myleshooveresq@gmail.cory
Counsel for Plaintiff Florida Dream Lands LLC
CERTIFICATE OF SERVICE
I hereby certify that pursuant to Florida Rule of Judicial Administration 2.516, a true and
correct copy of the foregoing has been furnished via the Florida E-portal as required pursuant to
Rule 1.080, Fla. R. Civ. P. on this day of November 9, 2023.
By:4/Myles A. Hoover.
MYLES A. HOOVER
8
Myles A. Hoover P.a.
Exhibit A
OFFICIAL RECORDS FILEM: 2376160 OR BK 3007 PG 1128 PAGES: 1
12/2/2023 1:22:18 PM REC FEES: $10,00 DEED DOC: $30.80
D.C, PGAMEZ1 JEROME KASZUBOWSKI CLERK OF COURTS, HIGHLANDS CO.
File No, 22000380
Patoel identification No. (-01-33-28-070-0110.0100
Tax Deed
STATE OF FLORIDA.
COUNTY OF HIGHLANDS
The following Tax Sale Certificate Numbered 776 lesued it June 1, 2018 was filed
County and opplicstion made for the ievance of a tax deed, the applicant having paid onor the offien of the Tux Collector of this
redeemed all ather taxes or tax sale
eertificates on the land described as required: by law to be pald or redeemed, and the costs
and expenses of this eile, and due notice
of ante having been published as requiredby law, and no person entitled to do so having appeared to redeem sinid Yond; such land
‘was soldan the Ist day of November 202% offered for sale as requiredby law for cash to the highest bidder and was sold ta:
cee DREAM LANDS LLC
1816 CHABBURY LOOP
DAVENPORT, FL33437
being the highest bidder und having ‘aiid the sum of their bid ge required by the Laws of Florida, NOW, this the Ind day of
Novensber 2023 County of Highlands, i State of Florida, in consideration of the sum of $4,400.00, being the amount paid paruant
Of the Laws nf Florida does hereby self the following lands situated in the County and State of foresaid and described ax follows:
LOTS 19 AND 20, BLOCK U, AVON PARK LAKES, RED HILL FARMS ADDITION, UNIT F, ACCORDING TO THE PLAT
THEREOF, AS RECORDED IN PLAT BOOK §, PAGES 49 AND 88, OF THE PUBLIC RECORDS
FLORIDA, GF HIGHLANDS COUNTY,
WITNESS;
*
Clerk of the Circuit
Court
HLINE FISHER oe BRs Highlands County, Florida
Rey Kets —
INDREA M. BURES
Terome Kaszubowski, Clark of the Court
STATE OF FLORIDA
COUNTY OF HIGHLANDS
The foregoing instrument was acknowl edged before mse this 2st day of Noverwber, 2023 by Jerome Kaszubawakil Clerk of the
Circuit Court, Highlands County, ‘Florida who ig personally imown 10 me
dimen
P Upseomt,
Notary Public
PreparedBy: i State of Florida.
Jerome Kaszubowski,
Clerk of the Circuit Court Expiews 8/2/2026 IAMES P LIPSCOMB.
580 S. Commerce Ave. Sebring, FL 33870
(863) 402-6586 NOTARY PUBLIC STATE OF FLORIDA
9
Myles A. Hoover P.a.
Exhibit B
191498
+ 159 wa S9
TRUSTEES ORRD
THES INDENTURE, made Unis wth say of, SePtamber an. & 82)
by und between WUE EL as Trusler
ander ued ty irtws of thoes eartaia True! A weith Avon Park I
& nan-proft Corporation af the Stata of Fhorlda, dated the Sist day of August, oF: pe.
A.D, 1956 and the
4th day of Jnmssary, AD, 1957, reapectivaly, amd receded in Oiiclul Recortt Bok 36, Prue 14 und
Oelnt Hecard Book 22, Pawe 4 HHS, Public. Reconts of Highlamte County, Plockle, hereinafter caida!
Party of the First Part, ane
SOVARD R. ROGAN and ROSE 8. HOGAN, buabsrd and wife
of the Countyof und Gate of Floride
hose pot wee hdres In DMG. 22th Avene South,
dake Worth, Flosida
smercnatiee cal Past to of tha Racond Part
WETNESSRTH, that aald Party of the Firet Part, for and tn consideration of the sum af Tun Dadlara
{HLOO0} amd other valuable votaiderations in hand pald, the receipt whereul ix herely weknowtaigsot.
‘ak ranted, bargained, sid asst Aranafarred, andty thene presents dows grunt, barmuin. rel wnt tramaler
unto thie Marts on of the Second fart nnd theme heirs anigna forever all Ueak certain
land tying and keine Ue the County of (Hatlnndn and State and af Flock, wore particslany deweribed pa
paver! af
atlas:
/
hots 19 and 20, tn Meck 12 + iit Na,
SSD WILL FARR AnOTTON
AvOe PARK LAKES/ncconting to plat thert reacded ja Plat Bouk 5 2 fame 69 & SS,
‘of Huphlandy County, Floris, tether wit appssrtanaracie Boeeesintie
hrelomging er im anhywine ining, inetadingy all right, tithe ape Inlewemt mf tbe yeeantir An
fad Gr any tant. tySig betwee aid
segs an mbsoer: Wy ast pat, rahjeet Totets eight and the eeater lise of amy atreots rile, aver it
of dedication roservesl in dhe grantor,
TO HAVE AND TO HOLD the tame in fer simple, Sti ‘BUEN an all rmapeets ty toe aneeral waers
‘rations, conemenis te Seon oy wetbl plat and ae meh forth im Nebectule “A einteal ow
the reverse side hereof and incorporated herain hy ratorencs,
‘Subject sineto taxes for the pear 1563 anil eubobquent yours.
ais ‘objise Yona Company,
{mo ot, xm anit mineral tests present tly Ko eitect on the Dole of anht woteltwintie
the bennfits of which, if any, nen
sata ote ‘oil ate ie previouny OF heldPinervedtrustty Parke
bySn Avon
the Centr ned
for
ai) ax may be determined Chamae st
the fy to st WHEREOP,
pent nak alec wl ihe sald Party of Use Pinte Part hes heenunto fet ie vk and een
enter
Sle sented nd disor
Ob Leese
STATE OF FLORIDA
COUNTY OF HIGHLANDS
A HERERY CERTIFY that oo this a ay of Yerober .
AD. 1962 . before me, the underaizned authority, rat RUE B, *
8 Trustee wader thon ‘Trust Agrestmania, an described tn the foregoing dead, the swvardleg of whieh
is relerred to herein for wll purposes, ta me well lmown te be the prrwemn decried (and who execated
the Toregsing tend of convayatia and ha acknowletired the execulhan tharee€ io be his free act and
‘ne foe the unee and purpoaen therets exprensee.
Hoa,the oy my404 alaatare apd official seal at Aven Pati
yoar last ataresnid,
in the County of Highlands and State of
Mir Roneminatan wepires:
ihe wese fF
moe hteot ie
tet an ten.
ot tags
WE,. 18S
Reno
10
Myles A. Hoover p.a
Exhibit C
OFFICIAL RECORDS FILE@: 2176161 OR BK 3007 PG 1129 PAGES: i
LL/2/2023 1:22:16 PM REC FRES: $16.60 DEED boc: $28.00
B.S. PGOAMEZ1 JEROME KASZUBOWSKI CLERK OF COURTS, HIGHLANDS CO.
File No. 23000363
Parcel identification No. C-20-36-30-160-6290-0160
Tax Deed
STATE OF FLORIDA.
COUNTY OF HIGHLANDS
‘The following Tax Sabe Certificate Numbered 8838 issued
in June 1, 2021 was fled on the offlee of the Tax Collector of this
County and application made toe the issumice of « tax dou, the applicant having pald or redeamed all other taxes of tax wale
eertiflcates on the land described as required by law to be pald or redeemed, and the costsand expenses of this sale, and due notice
of sale having been pablished as required by law, and no person entitled to do so ha appeared to redeem said land; sack land
was sold on the Jat day of Nowember 2023 offered for sale as required by law for cash to the highest bidder and was sold ter
FLOR! oe DREAM LANDS LLC
ADDI
1816 CHADBURY LOOP
DAVENPORT, FL33837
being the highest bidder and having paid the sum of their bid as required by the Laws of Florida. NOW, ‘this the Ind day of
November 2023 County of Highlands, State of Florida, in ion of ‘tht sum of $4,000.00, being the amount paid pursuant
of the Laws of Florida does hemby sell the following lands situated in‘the County and State of foresaid and described ay folhows:
LOTS 16 AND 17, BLOCK 23, HIGHLANDS P, "ARK ESTATES, SECTION B, ACCORDING TO THE FLAT THERKOR, AS
BRCORDED IN PLAT BOOK $, PAGE 17, 0F T hE PUBLIC RECORDS OF HIGHLANDS COUNTY, FLORIDA
WITNESS:
Clerk of the Circuit Court
NE FISHER Highlands Coumy, Florida
38
Sond
= Ket —
‘DREA M EURES sninentmernfm MoS eapemeenmnatia
Jerome Kaszubowski, Clerk of the Court
STATE OF FLORIDA
COUNTY OF HIGHLANDS
The instroment was acknowl before me this 2st day of November, 2023 by Jerome Kaszubowski, Clerk
of the
Cireult Court, Highlands County, Florida who is personally knownto me.
antes
© tipscoxnty
Prepared
By:
“ State
of Flory
er Some A276
Clerk of the Circuit
Court ae
590S. Commerce
Ave Sebring, FL
(863) 402. NOTARY PUBLIC STATE OF FLORIDA
11
Myles A. Hoover P.a.
Exhibit D
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Preview
Filing # 185861854 E-Filed 11/09/2023 03:44:36 PM IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT IN AND FOR HIGHLANDS COUNTY, FLORIDA CASE NO. FLORIDA DREAM LANDS, LLC., a Florida limited liability company, Plaintiff, VS. EDWARD R. HOGAN, if alive and if not his unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against EDWARD R. HOGAN; ROSE E. HOGAN, if alive and if not her unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against ROSE E. HOGAN; EDWIN P. DEFREYTAS, if alive and if not his unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against EDWIN P. DEFREYTAS; ELNA M. DEFREYTAS, if alive and if not her unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against ELNA M. DEFREYTAS; ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE THERETO, INCLUSIVE, Defendant(s). / COMPLAINT TO QUIET TITLE Plaintiff, FLORIDA DREAM LANDS, LLC., a Florida limited liability company, (hereinafter, the “Plaintiff” or “FL DREAM”), by and through their undersigned counsel, files this Complaint to quiet title against the Defendants, EDWARD R. HOGAN, if alive and if not his unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against EDWARD R. HOGAN, (“E HOGAN”); ROSE E. HOGAN, if alive and if not her unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under 1 Electronically Filed Highlands cose iyhey GARXNEY yey erego3pi4ge PM or against ROSE E. HOGAN, (“R HOGAN”); EDWIN P. DEFREYTAS, if alive and if not his unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against EDWIN P. DEFREYTAS, (“ED DEFREYTAS”); ELNA M. DEFREYTAS, if alive and if not her unknown spouse, heirs, devisees, grantees, creditors, or other parties claiming by, through, under or against ELNA M. DEFREYTAS, (“E DEFREYTAS”); and ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE THERETO, INCLUSIVE, (collectively, the “Defendants”), and alleges as follows: COUNTI 1 This is an action in which FL DREAM seeks to quiet its title to certain real property situated in Highlands County, Florida, filed pursuant to F.S. §65.081. Alternatively, in the event that the tax deed in the Plaintiffs chain of title are determined invalid as to the Defendants, EHOGAN, and R HOGAN, this is also an action to foreclose a statutory lien for such invalidated tax deed pursuant to the provisions of F.S. §197.602. FL DREAM does not know the true names of Defendant(s), ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE THERETO, INCLUSIVE. FL DREAM is the owner in fee simple of the following described land in Highlands County, Florida: 2 Myles A. Hoover P.a. A. LEGAL DESCRIPTION: LOTS 19 AND 20, BLOCK 11, AVON PARK LAKES, RED HILL FARMS ADDITION, UNIT F, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK 5, PAGES 49 AND 55, OF THE PUBLIC RECORDS OF HIGHLANDS COUNTY, FLORIDA. B. PARCEL #: C-01-33-28-070-0110-0190 C. ADDRESS: 2708 W KENOSHA RD, AVON PARK, FL 33825 4 None of the land constituting the subject matter of this suit is held by the U.S. Government or by the State of Florida and said Governmental bodies have relinquished or conveyed all of their rights, title or interest in and to said land and each and every parcel thereof, by patent, statute or other appropriate actions, as shown by entry in the Public Records of Highlands County, Florida. 5 DERAIGNMENT OF PLAINTIFFS’ TITLE: FL DREAM deraigns its title to the subject property as follows: (all recording data in this complaint refers to the public records of Highlands County, Florida, unless otherwise specified). A The Clerk of Circuit Court of Highlands County, Florida conveyed the above described property to the Plaintiff, FL DREAM, by Tax Deed dated November 1, 2023, and recorded on November 2, 2023, at Official Records Book 3007, Page 1128, of the Public Records of Highlands County, Florida. A copy of the Tax Deed is attached hereto and incorporated herein as Exhibit “A”. 6. CLAIMS OF DEFENDANTS: The claims of Defendants, E HOGAN, and R HOGAN, which casts a cloud or suspicion upon the title of FL DREAM are as follows: 3 Myles A. Hoover P.a. A Said land was conveyed to the Defendants, EHOGAN, and R HOGAN, by a Trustee’s Deed dated September 18, 1962, and executed by Hue E. Nunnallee, as the grantor. The Trustee’s Deed was recorded on November 7, 1962, at Official Records Book 159, Pages 159-160, of the Public Records of Highlands County, Florida. A copy of the Trustee’s Deed is attached hereto and incorporated herein as Exhibit “B”. 7 Any and all claims, rights, title or interest of the Defendants, E HOGAN, and R HOGAN, to the real property described above have been extinguished by the tax deed described herein, and FL DREAM is the true record title owner to the real property and the legal and equitable owner in fee simple, and is entitled to have its title to the real property quieted and confirmed by the Court under provision of F.S. §65.081. Pleading in the alternative, FL DREAM requests that if this court determines that the tax deed title issued to FL DREAM is void as to the Defendants, E HOGAN, and R HOGAN, that the Court determines in its final judgment that FL DREAM holds a good and valid lien on the subject real property for the amount of money paid by FL DREAM for the tax deed together with interests thereon at 12% per annum from the purchase, November 1, 2023, and the costs of this action, including attorney’s fees. WHEREFORE, FL DREAM, being without remedy save in a Court of equity prays as follows: A That upon final hearing, the fee simple title to the above-described property be adjudged to be in FL DREAM. B That the Defendants, EHOGAN, and R HOGAN, be required to set forth the nature of their claim in and to the above-described real property, and that all adverse claims by 4 Myles A. Hoover P.a. any Defendants or those claiming by, through, under or against any Defendant, be determined by a judgment of this court to be null and void as against FL DREAM. That all rights, title and interest of any Defendants and those parties claiming by, through, under or against any Defendant be forever quieted and confirmed in FL DREAM. That in the event the tax deed title of FL DREAM be invalidated, FL DREAM’s statutory lien for the amount paid for the tax deed together with interest from the date the tax deed was purchased, costs, and attorney’s fees be foreclosed and that the subject real property be sold by the Clerk of Courts to satisfy said lien. COUNT I This is an action in which FL DREAM seeks to quiet its title to certain real property situated in Highlands County, Florida, filed pursuant to F.S. §65.081. Alternatively, in the event that the tax deed in the Plaintiffs chain of title are determined invalid as to the Defendants, ED DEFREYTAS, and E DEFREYTAS, this is also an action to foreclose a statutory lien for such invalidated tax deed pursuant to the provisions of F.S. §197.602. 10. FL DREAM does not know the true names of Defendant(s), ALL PERSONS UNKNOWN, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, ESTATE, LIEN, OR INTEREST IN THE PROPERTY DESCRIBED IN THE COMPLAINT ADVERSE TO PLAINTIFF’S TITLE OR ANY CLOUD ON PLAINTIFF’S TITLE THERETO, INCLUSIVE. 11 FL DREAM is the owner in fee simple of the following described land in Highlands County, Florida: A. LEGAL DESCRIPTION: LOTS 16 AND 17, BLOCK 29, HIGHLANDS PARK ESTATES, SECTION R, ACCORDING TO THE PLAT 5 Myles A. Hoover P.a. THEREOF, AS RECORDED IN PLAT BOOK 5, PAGE 17, OF THE PUBLIC RECORDS OF HIGHLANDS COUNTY, FLORIDA. B PARCEL #: C-20-36-30-150-0290-0160 Cc ADDRESS: 1225 BRADLEY AVE, LAKE PLACID, FL 33852 12 None of the land constituting the subject matter of this suit is held by the U.S. Government or by the State of Florida and said Governmental bodies have relinquished or conveyed all of their rights, title or interest in and to said land and each and every parcel thereof, by patent, statute or other appropriate actions, as shown by entry in the Public Records of Highlands County, Florida. 13 DERAIGNMENT OF PLAINTIFFS’ TITLE: FL DREAM deraigns its title to the subject property as follows: (all recording data in this complaint refers to the public records of Highlands County, Florida, unless otherwise specified). A The Clerk of Circuit Court of Highlands County, Florida conveyed the above described property to the Plaintiff, FL DREAM, by Tax Deed dated November 1, 2023, and recorded on November 2, 2023, at Official Records Book 3007, Page 1129, of the Public Records of Highlands County, Florida. A copy of the Tax Deed is attached hereto and incorporated herein as Exhibit “C”. 14. CLAIMS OF DEFENDANTS: The claims of Defendants, ED DEFREYTAS, and E DEFREYTAS, which casts a cloud or suspicion upon the title of FL DREAM are as follows: A Said land was conveyed to the Defendants, ED DEFREYTAS, and E DEFREYTAS, by a Warranty Deed dated September 21, 1960, and executed by Highlands Downs, INC, as the grantor. The Warranty Deed was recorded on 6 Myles A. Hoover P.a. October 21, 1960, at Official Records Book 106, Page 403, of the Public Records of Highlands County, Florida. A copy of the Warranty Deed is attached hereto and incorporated herein as Exhibit “D”. 15 Any and all claims, rights, title or interest of the Defendants, ED DEFREYTAS, and E DEFREYTAS, to the real property described above have been extinguished by the tax deed described herein, and FL DREAM is the true record title owner to the real property and the legal and equitable owner in fee simple, and is entitled to have its title to the real property quieted and confirmed by the Court under provision of F.S. §65.081. 16 Pleading in the alternative, FL DREAM requests that if this court determines that the tax deed title issued to FL DREAM is void as to the Defendants, ED DEFREYTAS, and E DEFREYTAS, that the Court determines in its final judgment that FL DREAM holds a good and valid lien on the subject real property for the amount of money paid by FL DREAM for the tax deed together with interests thereon at 12% per annum from the purchase, November 1, 2023, and the costs of this action, including attorney’s fees. WHEREFORE, FL DREAM, being without remedy save in a Court of equity prays as follows: A That upon final hearing, the fee simple title to the above-described property be adjudged to be in FL DREAM. That the Defendants, ED DEFREYTAS, and E DEFREYTAS, be required to set forth the nature of their claim in and to the above-described real property, and that all adverse claims by any Defendants or those claiming by, through, under or against any Defendant, be determined by a judgment of this court to be null and void as against FL DREAM. 7 Myles A. Hoover P.a. Cc That all rights, title and interest of any Defendants and those parties claiming by, through, under or against any Defendant be forever quieted and confirmed in FL DREAM. That in the event the tax deed title of FL DREAM be invalidated, FL DREAM’s statutory lien for the amount paid for the tax deed together with interest from the date the tax deed was purchased, costs, and attorney’s fees be foreclosed and that the subject real property be sold by the Clerk of Courts to satisfy said lien. Respectfully submitted, MYLES A. HOOVER P.A. 11 Island Ave, # 406 Miami Beach, FL 33139 Telephone 786.312.0803 By:4/Myles A. Hoover MYLES A. HOOVER (FBN 1026217) Email: myleshooveresq@gmail.cory Counsel for Plaintiff Florida Dream Lands LLC CERTIFICATE OF SERVICE I hereby certify that pursuant to Florida Rule of Judicial Administration 2.516, a true and correct copy of the foregoing has been furnished via the Florida E-portal as required pursuant to Rule 1.080, Fla. R. Civ. P. on this day of November 9, 2023. By:4/Myles A. Hoover. MYLES A. HOOVER 8 Myles A. Hoover P.a. Exhibit A OFFICIAL RECORDS FILEM: 2376160 OR BK 3007 PG 1128 PAGES: 1 12/2/2023 1:22:18 PM REC FEES: $10,00 DEED DOC: $30.80 D.C, PGAMEZ1 JEROME KASZUBOWSKI CLERK OF COURTS, HIGHLANDS CO. File No, 22000380 Patoel identification No. (-01-33-28-070-0110.0100 Tax Deed STATE OF FLORIDA. COUNTY OF HIGHLANDS The following Tax Sale Certificate Numbered 776 lesued it June 1, 2018 was filed County and opplicstion made for the ievance of a tax deed, the applicant having paid onor the offien of the Tux Collector of this redeemed all ather taxes or tax sale eertificates on the land described as required: by law to be pald or redeemed, and the costs and expenses of this eile, and due notice of ante having been published as requiredby law, and no person entitled to do so having appeared to redeem sinid Yond; such land ‘was soldan the Ist day of November 202% offered for sale as requiredby law for cash to the highest bidder and was sold ta: cee DREAM LANDS LLC 1816 CHABBURY LOOP DAVENPORT, FL33437 being the highest bidder und having ‘aiid the sum of their bid ge required by the Laws of Florida, NOW, this the Ind day of Novensber 2023 County of Highlands, i State of Florida, in consideration of the sum of $4,400.00, being the amount paid paruant Of the Laws nf Florida does hereby self the following lands situated in the County and State of foresaid and described ax follows: LOTS 19 AND 20, BLOCK U, AVON PARK LAKES, RED HILL FARMS ADDITION, UNIT F, ACCORDING TO THE PLAT THEREOF, AS RECORDED IN PLAT BOOK §, PAGES 49 AND 88, OF THE PUBLIC RECORDS FLORIDA, GF HIGHLANDS COUNTY, WITNESS; * Clerk of the Circuit Court HLINE FISHER oe BRs Highlands County, Florida Rey Kets — INDREA M. BURES Terome Kaszubowski, Clark of the Court STATE OF FLORIDA COUNTY OF HIGHLANDS The foregoing instrument was acknowl edged before mse this 2st day of Noverwber, 2023 by Jerome Kaszubawakil Clerk of the Circuit Court, Highlands County, ‘Florida who ig personally imown 10 me dimen P Upseomt, Notary Public PreparedBy: i State of Florida. Jerome Kaszubowski, Clerk of the Circuit Court Expiews 8/2/2026 IAMES P LIPSCOMB. 580 S. Commerce Ave. Sebring, FL 33870 (863) 402-6586 NOTARY PUBLIC STATE OF FLORIDA 9 Myles A. Hoover P.a. Exhibit B 191498 + 159 wa S9 TRUSTEES ORRD THES INDENTURE, made Unis wth say of, SePtamber an. & 82) by und between WUE EL as Trusler ander ued ty irtws of thoes eartaia True! A weith Avon Park I & nan-proft Corporation af the Stata of Fhorlda, dated the Sist day of August, oF: pe. A.D, 1956 and the 4th day of Jnmssary, AD, 1957, reapectivaly, amd receded in Oiiclul Recortt Bok 36, Prue 14 und Oelnt Hecard Book 22, Pawe 4 HHS, Public. Reconts of Highlamte County, Plockle, hereinafter caida! Party of the First Part, ane SOVARD R. ROGAN and ROSE 8. HOGAN, buabsrd and wife of the Countyof und Gate of Floride hose pot wee hdres In DMG. 22th Avene South, dake Worth, Flosida smercnatiee cal Past to of tha Racond Part WETNESSRTH, that aald Party of the Firet Part, for and tn consideration of the sum af Tun Dadlara {HLOO0} amd other valuable votaiderations in hand pald, the receipt whereul ix herely weknowtaigsot. ‘ak ranted, bargained, sid asst Aranafarred, andty thene presents dows grunt, barmuin. rel wnt tramaler unto thie Marts on of the Second fart nnd theme heirs anigna forever all Ueak certain land tying and keine Ue the County of (Hatlnndn and State and af Flock, wore particslany deweribed pa paver! af atlas: / hots 19 and 20, tn Meck 12 + iit Na, SSD WILL FARR AnOTTON AvOe PARK LAKES/ncconting to plat thert reacded ja Plat Bouk 5 2 fame 69 & SS, ‘of Huphlandy County, Floris, tether wit appssrtanaracie Boeeesintie hrelomging er im anhywine ining, inetadingy all right, tithe ape Inlewemt mf tbe yeeantir An fad Gr any tant. tySig betwee aid segs an mbsoer: Wy ast pat, rahjeet Totets eight and the eeater lise of amy atreots rile, aver it of dedication roservesl in dhe grantor, TO HAVE AND TO HOLD the tame in fer simple, Sti ‘BUEN an all rmapeets ty toe aneeral waers ‘rations, conemenis te Seon oy wetbl plat and ae meh forth im Nebectule “A einteal ow the reverse side hereof and incorporated herain hy ratorencs, ‘Subject sineto taxes for the pear 1563 anil eubobquent yours. ais ‘objise Yona Company, {mo ot, xm anit mineral tests present tly Ko eitect on the Dole of anht woteltwintie the bennfits of which, if any, nen sata ote ‘oil ate ie previouny OF heldPinervedtrustty Parke bySn Avon the Centr ned for ai) ax may be determined Chamae st the fy to st WHEREOP, pent nak alec wl ihe sald Party of Use Pinte Part hes heenunto fet ie vk and een enter Sle sented nd disor Ob Leese STATE OF FLORIDA COUNTY OF HIGHLANDS A HERERY CERTIFY that oo this a ay of Yerober . AD. 1962 . before me, the underaizned authority, rat RUE B, * 8 Trustee wader thon ‘Trust Agrestmania, an described tn the foregoing dead, the swvardleg of whieh is relerred to herein for wll purposes, ta me well lmown te be the prrwemn decried (and who execated the Toregsing tend of convayatia and ha acknowletired the execulhan tharee€ io be his free act and ‘ne foe the unee and purpoaen therets exprensee. Hoa,the oy my404 alaatare apd official seal at Aven Pati yoar last ataresnid, in the County of Highlands and State of Mir Roneminatan wepires: ihe wese fF moe hteot ie tet an ten. ot tags WE,. 18S Reno 10 Myles A. Hoover p.a Exhibit C OFFICIAL RECORDS FILE@: 2176161 OR BK 3007 PG 1129 PAGES: i LL/2/2023 1:22:16 PM REC FRES: $16.60 DEED boc: $28.00 B.S. PGOAMEZ1 JEROME KASZUBOWSKI CLERK OF COURTS, HIGHLANDS CO. File No. 23000363 Parcel identification No. C-20-36-30-160-6290-0160 Tax Deed STATE OF FLORIDA. COUNTY OF HIGHLANDS ‘The following Tax Sabe Certificate Numbered 8838 issued in June 1, 2021 was fled on the offlee of the Tax Collector of this County and application made toe the issumice of « tax dou, the applicant having pald or redeamed all other taxes of tax wale eertiflcates on the land described as required by law to be pald or redeemed, and the costsand expenses of this sale, and due notice of sale having been pablished as required by law, and no person entitled to do so ha appeared to redeem said land; sack land was sold on the Jat day of Nowember 2023 offered for sale as required by law for cash to the highest bidder and was sold ter FLOR! oe DREAM LANDS LLC ADDI 1816 CHADBURY LOOP DAVENPORT, FL33837 being the highest bidder and having paid the sum of their bid as required by the Laws of Florida. NOW, ‘this the Ind day of November 2023 County of Highlands, State of Florida, in ion of ‘tht sum of $4,000.00, being the amount paid pursuant of the Laws of Florida does hemby sell the following lands situated in‘the County and State of foresaid and described ay folhows: LOTS 16 AND 17, BLOCK 23, HIGHLANDS P, "ARK ESTATES, SECTION B, ACCORDING TO THE FLAT THERKOR, AS BRCORDED IN PLAT BOOK $, PAGE 17, 0F T hE PUBLIC RECORDS OF HIGHLANDS COUNTY, FLORIDA WITNESS: Clerk of the Circuit Court NE FISHER Highlands Coumy, Florida 38 Sond = Ket — ‘DREA M EURES sninentmernfm MoS eapemeenmnatia Jerome Kaszubowski, Clerk of the Court STATE OF FLORIDA COUNTY OF HIGHLANDS The instroment was acknowl before me this 2st day of November, 2023 by Jerome Kaszubowski, Clerk of the Cireult Court, Highlands County, Florida who is personally knownto me. antes © tipscoxnty Prepared By: “ State of Flory er Some A276 Clerk of the Circuit Court ae 590S. Commerce Ave Sebring, FL (863) 402. NOTARY PUBLIC STATE OF FLORIDA 11 Myles A. Hoover P.a. Exhibit D oy wipe, oe ‘cine 44 “el IC, at ig. ARR SO POET Mier cae aa tom eatpee prenean "peeee a Os waieiakNE oo motuagames®ee naasonange scsi’ se hooey po ae he mau He gan se sd pod ng af ws pes hacmugaearay 2 {6 Sener ster oan sr 1 ee aad peer oe Be emrpsd pee oes trees 0 vo Joe Peo ‘anasel dear sof meee ee. 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Hoover p.a