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Filing # 28386758 E-Filed 06/11/2015 03:25:21 PM
IN THE CIRCUIT COURT OF THE TWELTH JUDICIAL CIRCUIT
IN AND FOR SARASOT A COUNTY, FLORIDA
WILLIAM H. BEHRENS,
Plaintiff, :
v. CASE NO: 2015-CA-2452-NC
BARBARA A. MORFORD
Defendant.
eevee rae ee RP re AC POAPIRALP PEYOTE ae ennai!
COMES NOW, Defendant, BARB. ARA, A. MORFORD, ) by and d through her undersigned
attorney and hereby answers the Complaint as follows:
GENERAL ALLEGATIONS
1. Admit for jurisdictional purposes only.
2. Admit. :
Denied.
Admit that property was mov ed into MORFORD’ residence.
Admit.
6. Admit that the parties’ eng age ement was terminated. Deny the remainder of
fe
LR
2
paragraph 6. :
7. Admit that MORPORD was ware of BEHRENS’ disability. Deny the remainder
of paragraph 7. /
8. Denied.
9. Admit Morford Revocable Trust was created. Deny the remainder of paragraph 9.
10. Admit that BEHR.
INS signed a Dur able Power of Attorney deny the remainder of
paragraph 10.
ll. Denied.
12. Denied.
13. Denied.
14. Admit.
yer ror enn yn PE REESE OO I RR
Filed 06/11/2015 03:42 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL16. Admit.
17. Denied.
18. Without knowledge and therefore denied.
19. Denied.
Count I
(Termination/Revocation of Trust)
20. Defendant restates and incorporates herein by reference her responses to
Paragraphs | through 19 of the General Allegations above as if fully written herein.
21. Admit for jurisdictional purposes only.
22. Denied.
23. Denied.
24, Denied.
25, Denied.
27. Denied.
COUNT
28. Defendant restates and incorporates herein by reference her responses to
Paragraph | through 19 of the General Allegations and Paragraphs 22 through 25 as if fully
rewritten herein.
29. Admit for jurisdictional purposes only.
30. Denied.
31. Denied.
bo
10s a siota ne veonrirves evenmeeanmernonnnren Tee yryrnmavenete rvevmeyen numnminnusnnyrnannet melarnaynlaMtatiautnabii'32. Defendant restates and incorporates herein by reference her responses to
Paragraphs | through 19 of the General Allegations and Paragraphs 22 through 25 above as if
fully rewritten herein.
33. Admit for jurisdictional purposes only.
35. _ Denied.
36. Denied.
37. ‘Denied.
COUNT IV
(Fraud)
38. . Defendant restates and incorp orates herein by reference her responses. to
Paragraphs 1 through 19 of the General Allegations, Paragraphs 22 through 25, 34, 35 and 36
above as if fully rewritten herein.
39. Without knowledge and therefore denied.
40. Denied.
41. Denied.
COUNTY
=
42. Defendant restates and incorporates. herein by reference her re sponses to
Paragraphs | through 19 of the General Allegations, Paragraphs 22 through 26, 30, 34, 35 and 36
above as if fully rewntten herein.
43. Admit that this appears to be a count for temporary injunction. Deny the
yemainder of paragraph 43.
44. — Admit for jurisdictional purposes only.
45. Denied.
46. Denied.
47. Denied.
Aad
1a cee NR Se a per ennai in rnin An A a Saye A ATEN INT eR48. —- Denied.
COUNT VI
(Conversion)
49. Defendant restates and incorporates herein by reference her responses to
ot
eneral Allegations, Paragraphs 11 through 26, 30, 34, 35 and 36
Paragraphs | through 19 of the C
above as if fully rewritten.
50. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any
elie
51. Denied.
COUNT VIL
(Replevin
52. Defendant restates and incorporates herein by reference her responses to
Paragraphs 1. through 19 of the General Allegations, Paragraphs 22 through 26, 30,34,35,36 and
45 above as if fully rewritten herein.
53. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any
relief.
S4. Denied.
55. Without knowledge and therefore denied.
56. Denied. -
57. Without knowledge and therefore denied.
58. Without knowledge and therefore denied.
COUNT VU
59, Defendant restates and incorporates herein by reference her responses to
Paragraphs | through. 19 of the General Al legations above as if fully rewritten herein.
60. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any
relief.
ne 8 Vee eee energie eee na eyeing wn tar ele lin in initia haa AN61. Admut that the parties traveled to California.
62. Denied.
63. Denied.
64. Denied.
65. Denied.
66. Denied.
67. Without knowledge and therefore denied. .
68. Admit that MORFORD returned to Florida.
69. Denied.
70. Denied.
71. Denied.
72. Defendant restates and incorporates herein by reference her responses to
Paragraphs 1 through 19 of the General Allegations, and Paragraphs 6 1 through 70 above as if
fully rewritten herein.
73. Admit that this appears to be a count for injunction/restraining order.
7A. Denied.
75. Denied.
76. Denied.
(Money Lent)
77. Defendant restates and incorporates herein by reference her responses to
Paragraphs | through 19 of the General Allegations above as is fully rewritten herein.
78. Admit that BEHRENS gave MORFORD money. Deny the remainder of
79. Denied.
80. Denied.
Aa he UROL an ein mim eet eyerinaietie a ala tarDefendant, BARBARA MORFORD, hereby denies each and every allegation not
specifically addressed above.
AFFIRS
Defendant, BARBARA MORFORD, hereby raises the following affirmative
JATIVE DEFENSES
FIRST AFFIRMATIVE DEFENSE
Defendant affirmatively alleges that Plaintiff is barred by the doctrine of unclean hands.
any statements made regarding domestic violence or an abusive relationship were the truth at the
time the statements were allegedly made.
THIRD AFFIRMATIVE DEFENSE
Detendant affirmatively alleges that all claims regarding undue influence are barred as
Plaintiff and Defendant consulted with a Trust and Estates attorney when drafting the trust and
power of attorney at issue in this lawsuit. Plaintiff as a result had the benefit of legal counsel and
cannot claim Defendant was responsible for explaining any legal concepts or documentation to
FOURTH AFFIRMATIVE DEFENSE
Defendant affirmatively alleges that any “money lent” to Defendant by Plaintiff was used
to pay household expenses, insurance premiums for Defendant, cell phone bills, and other
expenses common to both parties. No money is due to Defendant.
FIFTH AFFIRMATIVE DEFENSE
Defendant affirmatively alleges that Plaintiff has failed to comply with a conditions
precedent. In order to bring a claim for conversion. Plaintiff must demonstrate that they have
made a demand for return of the items at issue or in the alternative; they must allege that doing
so would be futile. Plaintiff has failed to demonstrate proof of this requirement.Lurene RRO ievenveyrnmanerta manana ane inne tet ere BEELER ES ESOT deg ce neers cane nonce Gf cect ite qua tenet tateurimenearasmnaneuens mane mineaaer rte caneriie Linea sana scans sit meager ces wans comes sheer ataie se eaweanena
SIXTH AFFIRMATIVE DEFENSE
Defendant affirmatively alleges that Plaintiff consented to Defendant possessing any of
his property. The parties have comingled assets and property throughout their relationship and
Plaintiff has consented to same.
Plaintiff and Defendant were engaged io be married and Defendant has subsequently
ended their relationship. This lawsuit is merely a retaliatory action by the Plaintiff.
.EFIRMATIVE DEFENSE
Asa separate and complete : af firmative defense, Defendant requests its attorney’s fees for
defending this action.
COMES NOW, Defendant, BARB ARA MORF ORD, by and d through h her + undersigned
attorney and hereby sues Plaintiff, WILLIAM H. BEHRENS, and alle ges as follows:
GENERAL ALLEGATIONS
1. ‘This is a Counterclaim for damages that exceed $15,000, exclusive of attorney’s
fees and costs.
2. This is a Counterclaim arising out of the same issues that are the subject of the
main claim.
3. At all times material hereto, BEHRENS and MORFORD were/ are residents of
Sarasota County, Florida.
4. The parties became engaged in. 2012
BEHRENS gave MORFORD an engagement ring as a Christmas gift in 2012.
ae
6. MORFORD paid for two wedding nngs. one for BEHRENS and one for herself,
Lye tn rn eG EAM PE nN a i i aT RN NN aE ATA AMET7. During their engagement, BEHRENS and MORFORD spent a majority of their
time at Morford’s home.
8. The home belonging to BEHRENS was used to store personal property of
MORFORD and BEHRENS during their engagement.
9, MORFORD and BEHRENS consulted a trust and estates attorney to draft the
Morford Revocable Trust and Durable Power of Attorney at issue.
10. | BEHRENS had the benefit of legal counsel when deciding to sign all
documentation relating to the Morford Revocable Trust and Durable Power of Attorney.
11. BEHRENS and MORFORD ended their relationship in February 2015.
12. BEHRENS retrieved all of his personal property that was in MORFORD's
possession subsequent to their relationship ending.
13. BEHRENS has failed or refused to return MORFORD’s personal property that is
in his posses sion.
COUNTI
14. MORFORD restates and incorporates herein. by reference paragraphs J through
13 of the General allegations above as if fully rewritten herein.
15. This is a count against William BEHRENS for slander per se.
16. This is an action for damages that exceed $15,000.
17. BEHRENS and MORFORD traveled to California in February 2015,
18. During their trip to California, BEHRENS physically assaulted MORFORD.
19. This was not the first time BEHRENS had physically assaulted MORFORD.
20. The police were called to the scene and an incident report was filed.21. Despite assaulting MORFORD, BEHRENS has told Kory MORFORD, and other
acquaintances of the parties that MORFORD attacked and assaulted him.
22. BEHRENS statements are false and were made by BEHRENS in an effort to
harm the reputation and relati onships of MO RFORD.
33. As a direct and proximate result of BEHRENS’ aforementioned actions,
WHEREFORE, MORFORD demands judgment against BEHRENS for
compensatory damages, special damages, costs and such other and further relief that the Court
deems just.
COUNT H
24. MORFORD restates and incorporates herein by reference Paragraphs | through
13 of the General Allegations as if fully rewritten herein.
25. This is an action against WILLLAM BEHRENS to recover personal property
believed to be located in Sarasota, County, Florida with a value that exceeds $15,000.
26. BEHRENS is holding all of MORFORD’s personal assets that were in the
BEHRENS property at the time the relations rip between. the partie s ended.
27. MORFORD's assets are being wrongfully detained by BEHRENS.
28. — A list of the property at issue is attached hereto as Exhibit “A.”
29, MORF ORD *s ‘personal property has not been taken for any ‘ax . secanen .
fine pursuant to law.
30. | MORFORD’s personal property and assets have not been taken under an
execution or attachment against the MORFORD assets and/ or personal property.
31. To date, BEHRENS has failed or refused to return MORFORD’s property.
9WHEREPORE, MORFORD. demands judgment against BEHRENS for possession of
the MORFORD assets and/or personal property, costs, and other such further relief as this Court
deems just.
COUNT HI
(Conversion)
32. MORFORD restates and incorporates herein by reference Paragraphs | through
13 of the General Allegations as if fully rewritten herein.
~
33. This is an action for damages that exceed $15,000.00.
34. Onor about February 10, 2015, BEHRENS converted to his own use the property
listed on the attached Exhibit “A” for his own use which was, at the time, the property of
35. Asa direct and proximate result of BEHRENS, MORFORD has suffered damages.
and will continue to suffer damages, including, but not limited to, the loss of the value of the
MORFORD assets converted by BEHRENS.
demands judgments against BEHRENS for compensatory
damages, interest, costs, and such other and further relief that the Court deems just.
10
commen ery inert neha AE ANSE na ARIE Ru ngs conet sce seas cones earth octane ate mieteat eneven ancien ern in nanan cama acumen nur atananaiee aneehs viens ean Teens coc agonmim gens cian ahs cans aah warts Sat tar nama ae wan amu wR ESR IEMA SNE SS whe eee pete STA carat en aN negJ HEREBY CERTIFY that a copy hereof has been furnished via e-mail to Randy L.
Merrit, Esq., RANDY L. MERRITT, ESQ., P.A., 5409 Downham Mdws, Sarasota, Fl 34235 a
rmerrittesq@ comcast.net on this | Ith day of June, 2015,
MORAN, SANCHY & ASSOCIATES
2197 Ringli ing Blvd.
Sarasota, FL 34237
P: P: (941) 366- -1§00
F: (94 1) 954-7101
Florida Bar No. 0714925
/s/ Kathryn Armstrong
Kathryn Armstrong, Esq.
Florida Bar No. 105703
klarmsi irongsrqlawé @email.com
Attorneys for Barbara Morford
ilMORFORD PROPERTY LIST
44 BOXES OF PERSONAL ITEMS- CLOTHING, HOUSEHOLD ITEMS ETC.
RADAR DETECTOR
BENCH FURNITURE WITH SHELLS.
LEATHER COUCH
TANDEM KAVAK
2 NEW KAYAK PADDLES
LL BEAN KAYAK CART
POLARIZED SNORKEL MASK AND SNORKELING GEAR
MEN’S 1 CARAT ENGAGEMENT RING
$100 CARRABAS GIFT CARD
3100 SHELL GAS CARD
PERSONAL ITEMS LEET IN MURINO
$400 CASH GIVEN TO BEHRENS FOR LAS VEGAS THAT WAS NEVER USED
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Filing # 28386758 E-Filed 06/11/2015 03:25:21 PM IN THE CIRCUIT COURT OF THE TWELTH JUDICIAL CIRCUIT IN AND FOR SARASOT A COUNTY, FLORIDA WILLIAM H. BEHRENS, Plaintiff, : v. CASE NO: 2015-CA-2452-NC BARBARA A. MORFORD Defendant. eevee rae ee RP re AC POAPIRALP PEYOTE ae ennai! COMES NOW, Defendant, BARB. ARA, A. MORFORD, ) by and d through her undersigned attorney and hereby answers the Complaint as follows: GENERAL ALLEGATIONS 1. Admit for jurisdictional purposes only. 2. Admit. : Denied. Admit that property was mov ed into MORFORD’ residence. Admit. 6. Admit that the parties’ eng age ement was terminated. Deny the remainder of fe LR 2 paragraph 6. : 7. Admit that MORPORD was ware of BEHRENS’ disability. Deny the remainder of paragraph 7. / 8. Denied. 9. Admit Morford Revocable Trust was created. Deny the remainder of paragraph 9. 10. Admit that BEHR. INS signed a Dur able Power of Attorney deny the remainder of paragraph 10. ll. Denied. 12. Denied. 13. Denied. 14. Admit. yer ror enn yn PE REESE OO I RR Filed 06/11/2015 03:42 PM - Karen E. Rushing, Clerk of the Circuit Court, Sarasota County, FL16. Admit. 17. Denied. 18. Without knowledge and therefore denied. 19. Denied. Count I (Termination/Revocation of Trust) 20. Defendant restates and incorporates herein by reference her responses to Paragraphs | through 19 of the General Allegations above as if fully written herein. 21. Admit for jurisdictional purposes only. 22. Denied. 23. Denied. 24, Denied. 25, Denied. 27. Denied. COUNT 28. Defendant restates and incorporates herein by reference her responses to Paragraph | through 19 of the General Allegations and Paragraphs 22 through 25 as if fully rewritten herein. 29. Admit for jurisdictional purposes only. 30. Denied. 31. Denied. bo 10s a siota ne veonrirves evenmeeanmernonnnren Tee yryrnmavenete rvevmeyen numnminnusnnyrnannet melarnaynlaMtatiautnabii'32. Defendant restates and incorporates herein by reference her responses to Paragraphs | through 19 of the General Allegations and Paragraphs 22 through 25 above as if fully rewritten herein. 33. Admit for jurisdictional purposes only. 35. _ Denied. 36. Denied. 37. ‘Denied. COUNT IV (Fraud) 38. . Defendant restates and incorp orates herein by reference her responses. to Paragraphs 1 through 19 of the General Allegations, Paragraphs 22 through 25, 34, 35 and 36 above as if fully rewritten herein. 39. Without knowledge and therefore denied. 40. Denied. 41. Denied. COUNTY = 42. Defendant restates and incorporates. herein by reference her re sponses to Paragraphs | through 19 of the General Allegations, Paragraphs 22 through 26, 30, 34, 35 and 36 above as if fully rewntten herein. 43. Admit that this appears to be a count for temporary injunction. Deny the yemainder of paragraph 43. 44. — Admit for jurisdictional purposes only. 45. Denied. 46. Denied. 47. Denied. Aad 1a cee NR Se a per ennai in rnin An A a Saye A ATEN INT eR48. —- Denied. COUNT VI (Conversion) 49. Defendant restates and incorporates herein by reference her responses to ot eneral Allegations, Paragraphs 11 through 26, 30, 34, 35 and 36 Paragraphs | through 19 of the C above as if fully rewritten. 50. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any elie 51. Denied. COUNT VIL (Replevin 52. Defendant restates and incorporates herein by reference her responses to Paragraphs 1. through 19 of the General Allegations, Paragraphs 22 through 26, 30,34,35,36 and 45 above as if fully rewritten herein. 53. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any relief. S4. Denied. 55. Without knowledge and therefore denied. 56. Denied. - 57. Without knowledge and therefore denied. 58. Without knowledge and therefore denied. COUNT VU 59, Defendant restates and incorporates herein by reference her responses to Paragraphs | through. 19 of the General Al legations above as if fully rewritten herein. 60. Admit for jurisdictional purposes only. Denied that Plaintiff is entitled to any relief. ne 8 Vee eee energie eee na eyeing wn tar ele lin in initia haa AN61. Admut that the parties traveled to California. 62. Denied. 63. Denied. 64. Denied. 65. Denied. 66. Denied. 67. Without knowledge and therefore denied. . 68. Admit that MORFORD returned to Florida. 69. Denied. 70. Denied. 71. Denied. 72. Defendant restates and incorporates herein by reference her responses to Paragraphs 1 through 19 of the General Allegations, and Paragraphs 6 1 through 70 above as if fully rewritten herein. 73. Admit that this appears to be a count for injunction/restraining order. 7A. Denied. 75. Denied. 76. Denied. (Money Lent) 77. Defendant restates and incorporates herein by reference her responses to Paragraphs | through 19 of the General Allegations above as is fully rewritten herein. 78. Admit that BEHRENS gave MORFORD money. Deny the remainder of 79. Denied. 80. Denied. Aa he UROL an ein mim eet eyerinaietie a ala tarDefendant, BARBARA MORFORD, hereby denies each and every allegation not specifically addressed above. AFFIRS Defendant, BARBARA MORFORD, hereby raises the following affirmative JATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE Defendant affirmatively alleges that Plaintiff is barred by the doctrine of unclean hands. any statements made regarding domestic violence or an abusive relationship were the truth at the time the statements were allegedly made. THIRD AFFIRMATIVE DEFENSE Detendant affirmatively alleges that all claims regarding undue influence are barred as Plaintiff and Defendant consulted with a Trust and Estates attorney when drafting the trust and power of attorney at issue in this lawsuit. Plaintiff as a result had the benefit of legal counsel and cannot claim Defendant was responsible for explaining any legal concepts or documentation to FOURTH AFFIRMATIVE DEFENSE Defendant affirmatively alleges that any “money lent” to Defendant by Plaintiff was used to pay household expenses, insurance premiums for Defendant, cell phone bills, and other expenses common to both parties. No money is due to Defendant. FIFTH AFFIRMATIVE DEFENSE Defendant affirmatively alleges that Plaintiff has failed to comply with a conditions precedent. In order to bring a claim for conversion. Plaintiff must demonstrate that they have made a demand for return of the items at issue or in the alternative; they must allege that doing so would be futile. Plaintiff has failed to demonstrate proof of this requirement.Lurene RRO ievenveyrnmanerta manana ane inne tet ere BEELER ES ESOT deg ce neers cane nonce Gf cect ite qua tenet tateurimenearasmnaneuens mane mineaaer rte caneriie Linea sana scans sit meager ces wans comes sheer ataie se eaweanena SIXTH AFFIRMATIVE DEFENSE Defendant affirmatively alleges that Plaintiff consented to Defendant possessing any of his property. The parties have comingled assets and property throughout their relationship and Plaintiff has consented to same. Plaintiff and Defendant were engaged io be married and Defendant has subsequently ended their relationship. This lawsuit is merely a retaliatory action by the Plaintiff. .EFIRMATIVE DEFENSE Asa separate and complete : af firmative defense, Defendant requests its attorney’s fees for defending this action. COMES NOW, Defendant, BARB ARA MORF ORD, by and d through h her + undersigned attorney and hereby sues Plaintiff, WILLIAM H. BEHRENS, and alle ges as follows: GENERAL ALLEGATIONS 1. ‘This is a Counterclaim for damages that exceed $15,000, exclusive of attorney’s fees and costs. 2. This is a Counterclaim arising out of the same issues that are the subject of the main claim. 3. At all times material hereto, BEHRENS and MORFORD were/ are residents of Sarasota County, Florida. 4. The parties became engaged in. 2012 BEHRENS gave MORFORD an engagement ring as a Christmas gift in 2012. ae 6. MORFORD paid for two wedding nngs. one for BEHRENS and one for herself, Lye tn rn eG EAM PE nN a i i aT RN NN aE ATA AMET7. During their engagement, BEHRENS and MORFORD spent a majority of their time at Morford’s home. 8. The home belonging to BEHRENS was used to store personal property of MORFORD and BEHRENS during their engagement. 9, MORFORD and BEHRENS consulted a trust and estates attorney to draft the Morford Revocable Trust and Durable Power of Attorney at issue. 10. | BEHRENS had the benefit of legal counsel when deciding to sign all documentation relating to the Morford Revocable Trust and Durable Power of Attorney. 11. BEHRENS and MORFORD ended their relationship in February 2015. 12. BEHRENS retrieved all of his personal property that was in MORFORD's possession subsequent to their relationship ending. 13. BEHRENS has failed or refused to return MORFORD’s personal property that is in his posses sion. COUNTI 14. MORFORD restates and incorporates herein. by reference paragraphs J through 13 of the General allegations above as if fully rewritten herein. 15. This is a count against William BEHRENS for slander per se. 16. This is an action for damages that exceed $15,000. 17. BEHRENS and MORFORD traveled to California in February 2015, 18. During their trip to California, BEHRENS physically assaulted MORFORD. 19. This was not the first time BEHRENS had physically assaulted MORFORD. 20. The police were called to the scene and an incident report was filed.21. Despite assaulting MORFORD, BEHRENS has told Kory MORFORD, and other acquaintances of the parties that MORFORD attacked and assaulted him. 22. BEHRENS statements are false and were made by BEHRENS in an effort to harm the reputation and relati onships of MO RFORD. 33. As a direct and proximate result of BEHRENS’ aforementioned actions, WHEREFORE, MORFORD demands judgment against BEHRENS for compensatory damages, special damages, costs and such other and further relief that the Court deems just. COUNT H 24. MORFORD restates and incorporates herein by reference Paragraphs | through 13 of the General Allegations as if fully rewritten herein. 25. This is an action against WILLLAM BEHRENS to recover personal property believed to be located in Sarasota, County, Florida with a value that exceeds $15,000. 26. BEHRENS is holding all of MORFORD’s personal assets that were in the BEHRENS property at the time the relations rip between. the partie s ended. 27. MORFORD's assets are being wrongfully detained by BEHRENS. 28. — A list of the property at issue is attached hereto as Exhibit “A.” 29, MORF ORD *s ‘personal property has not been taken for any ‘ax . secanen . fine pursuant to law. 30. | MORFORD’s personal property and assets have not been taken under an execution or attachment against the MORFORD assets and/ or personal property. 31. To date, BEHRENS has failed or refused to return MORFORD’s property. 9WHEREPORE, MORFORD. demands judgment against BEHRENS for possession of the MORFORD assets and/or personal property, costs, and other such further relief as this Court deems just. COUNT HI (Conversion) 32. MORFORD restates and incorporates herein by reference Paragraphs | through 13 of the General Allegations as if fully rewritten herein. ~ 33. This is an action for damages that exceed $15,000.00. 34. Onor about February 10, 2015, BEHRENS converted to his own use the property listed on the attached Exhibit “A” for his own use which was, at the time, the property of 35. Asa direct and proximate result of BEHRENS, MORFORD has suffered damages. and will continue to suffer damages, including, but not limited to, the loss of the value of the MORFORD assets converted by BEHRENS. demands judgments against BEHRENS for compensatory damages, interest, costs, and such other and further relief that the Court deems just. 10 commen ery inert neha AE ANSE na ARIE Ru ngs conet sce seas cones earth octane ate mieteat eneven ancien ern in nanan cama acumen nur atananaiee aneehs viens ean Teens coc agonmim gens cian ahs cans aah warts Sat tar nama ae wan amu wR ESR IEMA SNE SS whe eee pete STA carat en aN negJ HEREBY CERTIFY that a copy hereof has been furnished via e-mail to Randy L. Merrit, Esq., RANDY L. MERRITT, ESQ., P.A., 5409 Downham Mdws, Sarasota, Fl 34235 a rmerrittesq@ comcast.net on this | Ith day of June, 2015, MORAN, SANCHY & ASSOCIATES 2197 Ringli ing Blvd. Sarasota, FL 34237 P: P: (941) 366- -1§00 F: (94 1) 954-7101 Florida Bar No. 0714925 /s/ Kathryn Armstrong Kathryn Armstrong, Esq. Florida Bar No. 105703 klarmsi irongsrqlawé @email.com Attorneys for Barbara Morford ilMORFORD PROPERTY LIST 44 BOXES OF PERSONAL ITEMS- CLOTHING, HOUSEHOLD ITEMS ETC. RADAR DETECTOR BENCH FURNITURE WITH SHELLS. LEATHER COUCH TANDEM KAVAK 2 NEW KAYAK PADDLES LL BEAN KAYAK CART POLARIZED SNORKEL MASK AND SNORKELING GEAR MEN’S 1 CARAT ENGAGEMENT RING $100 CARRABAS GIFT CARD 3100 SHELL GAS CARD PERSONAL ITEMS LEET IN MURINO $400 CASH GIVEN TO BEHRENS FOR LAS VEGAS THAT WAS NEVER USED