On May 01, 2015 a
Answer
was filed
involving a dispute between
Behrens, William H,
and
Morford, Barbara A,
for REPLEVIN - CIRCUIT 2010
in the District Court of Sarasota County.
Preview
Filing # 65239141 E-Filed 12/11/2017 04:19:02 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT OF
FLORIDA, IN AND FOR SARASOTA COUNTY, FLORIDA
WILLIAM H. BEHRENS,
Plaintiff,
V. CASE NO. 2015-CA-2452-NC
BARBARA A, MOREFORD
Defendant.
ANSWER TO DEFENDANT’S COUNTERCLAIM
Plaintiff/Counter-Defendant William Behrens answers the Counter-Claim filed by
Defendant/Counter-Plaintiff Barbara A. Moreford and says:
Without Knowledge.
Without Knowledge.
Without Knowledge.
Denied.
Denied.
MW PWN PE
COUNT I - BATTERY
>
In response to paragraph 6, Counter-Defendant realleges his responses to paragraphs |
through 5 and incorporates them herein by reference.
Denied.
Denied.
Denied.
0. Denied.
= we eN
COUNT 2- ASSAULT
11. In response to paragraph 11, Counter-Defendant realleges his responses to paragraphs 1
through 5 and incorporates them herein by reference.
12. Denied.
13. Denied.
14. Denied.
15. Denied.
COUNT 3 — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
Filed 12/11/2017 04:44 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL16.
17.
18.
19,
20.
21.
22,
23.
24.
25.
In response to paragraph 16, Counter-Defendant realleges his responses to paragraphs 1
through 5 and incorporates them herein by reference.
Denied.
Denied.
Denied.
Denied.
COUNT 4 —- NEGLIGENCE
In response to paragraph 21, Counter-Defendant realleges his responses to paragraphs 1
through 5 and incorporates them herein by reference.
Denied.
Denied.
Denied.
Denied.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true copy of the foregoing has been furnished via Email this
11" Day of December, 2017 to Vincent Gannuscio through the e-filing portal.
LAW OFFICE OF THOMAS M. FITZGIBBONS
/s/ Thomas M. Fitzgibbons
THOMAS M. FITZGIBBONS, ESQUIRE
2750 Ringling Boulevard
Suite 4
Sarasota, FL 34237
Phone: (941) 953-5697
Fax: (941) 951-0279
Thomas(@FitzeibbonsLawOffice.com
Attorney for Plaintiff
FL Bar No.: 0229210
Document Filed Date
December 11, 2017
Case Filing Date
May 01, 2015
Category
REPLEVIN - CIRCUIT 2010
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 65239141 E-Filed 12/11/2017 04:19:02 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR SARASOTA COUNTY, FLORIDA WILLIAM H. BEHRENS, Plaintiff, V. CASE NO. 2015-CA-2452-NC BARBARA A, MOREFORD Defendant. ANSWER TO DEFENDANT’S COUNTERCLAIM Plaintiff/Counter-Defendant William Behrens answers the Counter-Claim filed by Defendant/Counter-Plaintiff Barbara A. Moreford and says: Without Knowledge. Without Knowledge. Without Knowledge. Denied. Denied. MW PWN PE COUNT I - BATTERY > In response to paragraph 6, Counter-Defendant realleges his responses to paragraphs | through 5 and incorporates them herein by reference. Denied. Denied. Denied. 0. Denied. = we eN COUNT 2- ASSAULT 11. In response to paragraph 11, Counter-Defendant realleges his responses to paragraphs 1 through 5 and incorporates them herein by reference. 12. Denied. 13. Denied. 14. Denied. 15. Denied. COUNT 3 — INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS Filed 12/11/2017 04:44 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL16. 17. 18. 19, 20. 21. 22, 23. 24. 25. In response to paragraph 16, Counter-Defendant realleges his responses to paragraphs 1 through 5 and incorporates them herein by reference. Denied. Denied. Denied. Denied. COUNT 4 —- NEGLIGENCE In response to paragraph 21, Counter-Defendant realleges his responses to paragraphs 1 through 5 and incorporates them herein by reference. Denied. Denied. Denied. Denied. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has been furnished via Email this 11" Day of December, 2017 to Vincent Gannuscio through the e-filing portal. LAW OFFICE OF THOMAS M. FITZGIBBONS /s/ Thomas M. Fitzgibbons THOMAS M. FITZGIBBONS, ESQUIRE 2750 Ringling Boulevard Suite 4 Sarasota, FL 34237 Phone: (941) 953-5697 Fax: (941) 951-0279 Thomas(@FitzeibbonsLawOffice.com Attorney for Plaintiff FL Bar No.: 0229210