On January 14, 2019 a
Answer
was filed
involving a dispute between
Reverse Mortgage Solutions Inc,
and
Eason, Pam,
Holland, John Walter,
Mccallum, Phyllis Ann,
Morris, Chuck,
Morris, Rick,
The Unknown Heirs Beneficiarie,
The Unknown Successor Trustee,
United States Of America,
for Circuit Civil 3-C
in the District Court of Marion County.
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Filing # 84724399 E-Filed 02/11/2019 02:11:53 PM
IN THE CIRCUIT COURT OF THE FIFTH
JUDICIAL CIRCUIT IN AND FOR MARION
COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.:
REVERSE MORTGAGE SOLUTIONS,
INC.,
Plaintiff,
vs.
THE UNKNOWN HEIRS,
BENFICIARIES, DEVISEES,
GRANTEES, ASSIGNEES, LIENORS,
CREDITORS, TRUSTEES AND ALL
OTHERS WHO MAY CLAIM AN
INTEREST IN THE ESTATE OF LEROY
C. REIF, DECEASED; THE UNKNOWN
SUCCESSOR TRUSTEE OF THE
HOLLAND FAMILY LIVING TRUST,
DATED APRIL 3, 1998; JOHN WALTER
HOLLAND; CHUCK MORRIS; PAM
EASON; SHARON VORHERR; RICK
MORRIS; PHYLLIS ANN MCCALLUM;
THE UNKNOWN HEIRS,
BENEFICIARIES, DEVISEES, GRANTEEES,
ASSIGNEES, LIENORS, CREDITORS,
TRUSTEES AND ALL OTHERS WHO MAY
CLAIM AN INTEREST IN THE ESTATE
OF PEGGY J. REIF F/K/A PEGGY J.
HOLLAND, DECEASED; UNITED STATES
OF AMERICA ACTING ON BEHALF OF
THE SECRETARY OF HOUSING AND
URBAN DEVELOPMENT,
Defendant(s).
ANSWER ON BEHALF OF DEFENDANT
SHARON VORHERR
COMES NOW Sharon Vorherr, Defendant in the above-styled action and makes this her Answer
to Plaintiff's Complaint as follows:
FIRST DEFENSE
Electronically Filed Marion Case # 19CA000106AX 02/11/2019 02:11:53 PM
Plaintiff fails to state a claim against this Defendant upon which relief can be granted.
SECOND DEFENSE
Venue is improper as to this Defendant.
COUNT 1 - MORTGAGE FORECLOSURE
Admitted.
Defendant admits the named property is located in Marion County, Florida, but denies that she is
subject to the jurisdiction of this Court.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 3.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 4.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 5.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 6.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 7.
Admitted.
Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 9.
10. Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 10.
11 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 11.
12 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 12.
13 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 13.
14 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 14.
15 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 15.
16 Upon information and belief, it is admitted John Walter Holland was an individual included in the
Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or
information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 16.
17. Upon information and belief, it is admitted Chuck Morris was an individual included in the
Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or
information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 17.
18 Upon information and belief, it is admitted Pam Eason was an individual included in the Holland
Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information
sufficient to form a belief as to the truth of the remaining allegations of Paragraph 18.
19 Upon information and belief, it is admitted Sharon Vorherr was an individual included in the
Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or
information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 19.
20. Upon information and belief, it is admitted Rick Morris was an individual included in the Holland
Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information
sufficient to form a belief as to the truth of the remaining allegations of Paragraph 20.
21 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 21.
22 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 22.
23 Defendant is without knowledge or information sufficient to form a belief as to the truth of the
allegations of Paragraph 23.
Any allegations not specifically address above are hereby denied.
WHEREFORE having answered each and every paragraph of Plaintiff's Complaint, this
defendant prays that she have a trial by a jury of twelve persons and be dismissed with her costs.
This 11" day of February, 2019.
/s/ M. Katelyn Vorherr
M. KATELYN VORHERR
Florida Bar No.: 103188
Attorney for Defendant, Sharon Vorherr
521 Laurenburg Drive
Richmond Hill, GA 31324
PH (678) 425-4900
katelyn.vorherr(@email.com
Document Filed Date
February 11, 2019
Case Filing Date
January 14, 2019
Category
Circuit Civil 3-C
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Filing # 84724399 E-Filed 02/11/2019 02:11:53 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR MARION COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: REVERSE MORTGAGE SOLUTIONS, INC., Plaintiff, vs. THE UNKNOWN HEIRS, BENFICIARIES, DEVISEES, GRANTEES, ASSIGNEES, LIENORS, CREDITORS, TRUSTEES AND ALL OTHERS WHO MAY CLAIM AN INTEREST IN THE ESTATE OF LEROY C. REIF, DECEASED; THE UNKNOWN SUCCESSOR TRUSTEE OF THE HOLLAND FAMILY LIVING TRUST, DATED APRIL 3, 1998; JOHN WALTER HOLLAND; CHUCK MORRIS; PAM EASON; SHARON VORHERR; RICK MORRIS; PHYLLIS ANN MCCALLUM; THE UNKNOWN HEIRS, BENEFICIARIES, DEVISEES, GRANTEEES, ASSIGNEES, LIENORS, CREDITORS, TRUSTEES AND ALL OTHERS WHO MAY CLAIM AN INTEREST IN THE ESTATE OF PEGGY J. REIF F/K/A PEGGY J. HOLLAND, DECEASED; UNITED STATES OF AMERICA ACTING ON BEHALF OF THE SECRETARY OF HOUSING AND URBAN DEVELOPMENT, Defendant(s). ANSWER ON BEHALF OF DEFENDANT SHARON VORHERR COMES NOW Sharon Vorherr, Defendant in the above-styled action and makes this her Answer to Plaintiff's Complaint as follows: FIRST DEFENSE Electronically Filed Marion Case # 19CA000106AX 02/11/2019 02:11:53 PM Plaintiff fails to state a claim against this Defendant upon which relief can be granted. SECOND DEFENSE Venue is improper as to this Defendant. COUNT 1 - MORTGAGE FORECLOSURE Admitted. Defendant admits the named property is located in Marion County, Florida, but denies that she is subject to the jurisdiction of this Court. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 3. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 4. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 5. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 6. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 7. Admitted. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 9. 10. Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 10. 11 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 11. 12 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 12. 13 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 13. 14 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 14. 15 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 15. 16 Upon information and belief, it is admitted John Walter Holland was an individual included in the Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 16. 17. Upon information and belief, it is admitted Chuck Morris was an individual included in the Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 17. 18 Upon information and belief, it is admitted Pam Eason was an individual included in the Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 18. 19 Upon information and belief, it is admitted Sharon Vorherr was an individual included in the Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 19. 20. Upon information and belief, it is admitted Rick Morris was an individual included in the Holland Family Living Trust, Dated April 3, 1998. Defendant is without knowledge or information sufficient to form a belief as to the truth of the remaining allegations of Paragraph 20. 21 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 21. 22 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 22. 23 Defendant is without knowledge or information sufficient to form a belief as to the truth of the allegations of Paragraph 23. Any allegations not specifically address above are hereby denied. WHEREFORE having answered each and every paragraph of Plaintiff's Complaint, this defendant prays that she have a trial by a jury of twelve persons and be dismissed with her costs. This 11" day of February, 2019. /s/ M. Katelyn Vorherr M. KATELYN VORHERR Florida Bar No.: 103188 Attorney for Defendant, Sharon Vorherr 521 Laurenburg Drive Richmond Hill, GA 31324 PH (678) 425-4900 katelyn.vorherr(@email.com