On June 26, 1979 a
Answer
was filed
involving a dispute between
Louis Anthony Wasylik, As Successor Trustee Of The,
Louis Anthony Wasylik, As Trustee Of The Louis Ant,
and
All Other Persons Who Have Or May Claim An Interes,
Beachcomber Bungalows Of Manasota Key, Llc,
Beachcomber Hideaways Of Manasota Key, Llc,
Goetz, Gregory W,
Gwizdz, Stanley,
Shark'S Tooth Properties, Inc.,
for Quiet Title < $50K
in the District Court of Charlotte County.
Preview
Filing # 146431402 E-Filed 03/25/2022 12:12:26 PM
IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
LOUIS ANTHONY WASYLIK,
AS TRUSTEE OF THE LOUIS
ANTHONY WASYLIK REVOCABLE
TRUST DATED MAY 23, 2000 AND
AS SUCCESSOR TRUSTEE OF THE
ALICE JEAN WASYLIK REVOCABLE
TRUST DATED MAY 23, 2000,
Plaintiff,
vs. CASE NO: 21-CA-725
SHARK’S TOOTH PROPERTIES, INC.,
A FLORIDA CORPORATION; et al,
Defendants,
ANSWER OF GUARDIAN AD LITEM,
ADMINISTRATOR AD LITEM AND ATTORNEY AD LITEM
COMES NOW, JAMES L. GOETZ, after having been appointed Guardian
Ad Litem, Administrator Ad Litem and Attorney Ad Litem (hereafter referred to as
Guardian) to represent Defendant, MARIA GWIZDZ; MARIA GWIZDZ, AS
SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ INTER VIVOS TRUST
DATED DECEMBER 21, 2017 AND MARIA GWIZDZ, AS TRUSTEE OF THE
MARIA GWIZDZ LIVING TRUST U/A DATED DECEMBER 21, 2017; if any, and
determining elsewhere to the best of his ability the facts in this cause, answers
as follows:
4 Guardian admits to paragraph 1 of Plaintiffs Complaint for
jurisdictional purposes only.
2. Guardian has no knowledge of paragraph 2 of Plaintiff's Complaint
and therefore denies
3. Guardian has no knowledge of paragraph 3 of Plaintiff's Complaint
and therefore denies
4. Guardian has no knowledge of paragraph 4 of Plaintiffs Complaint
and therefore denies.
5. Guardian has no knowledge of paragraph 5 of Plaintiffs Complaint
and therefore denies.
6. Guardian has no knowledge of paragraph 6 of Plaintiff's Complaint
and therefore denies.
7. Guardian has no knowledge of paragraph 7 of Plaintiff's Complaint
and therefore denies.
8. Guardian has no knowledge of paragraph 8 of Plaintiff's Complaint
and therefore denies.
9. Guardian has no knowledge of paragraph 9 of Plaintiffs Complaint
and therefore denies.
10. Guardian has no knowledge of paragraph 10 of Plaintiffs Complaint
and therefore denies.
11. Guardian has no knowledge of paragraph 11 of Plaintiffs Complaint
and therefore denies.
12. Guardian has no knowledge of paragraph 12 of Plaintiff's Complaint
and therefore denies.
13. Guardian has no knowledge of paragraph 13 of Plaintiff's Complaint
and therefore denies
14. Guardian has no knowledge of paragraph 14 of Plaintiffs Complaint
and therefore denies.
15. Guardian has no knowledge of paragraph 15 of Plaintiffs Complaint
and therefore denies.
16. Guardian has no knowledge of paragraph 16 of Plaintiffs Complaint
and therefore denies.
17. Guardian has no knowledge of paragraph 17 of Plaintiff's Complaint
and therefore denies.
18. Guardian has no knowledge of paragraph 18 of Plaintiff's Complaint
and therefore denies.
19. Guardian has no knowledge of paragraph 19 of Plaintiff's Complaint
and therefore denies.
20. Guardian has no knowledge of paragraph 20 of Plaintiff's Complaint
and therefore denies.
21. Guardian has no knowledge of paragraph 21 of Plaintiff's Complaint
and therefore denies.
22, Guardian has no knowledge of paragraph 22 of Plaintiffs Complaint
and therefore denies.
23. Guardian has no knowledge of paragraph 23 of Plaintiffs Complaint
and therefore denies
24. Guardian has no knowledge of paragraph 24 of Plaintiffs Complaint
and therefore denies.
25. Guardian has no knowledge of paragraph 25 of Plaintiff's Complaint
and therefore denies.
26. Guardian has no knowledge of paragraph 26 of Plaintiffs Complaint
and therefore denies.
27. Guardian has no knowledge of paragraph 27 of Plaintiffs Complaint
and therefore denies.
28. Guardian has no knowledge of paragraph 28 of Plaintiff's Complaint
and therefore denies.
29. Guardian has no knowledge of paragraph 29 of Plaintiff's Complaint
and therefore denies.
30. Guardian has no knowledge of paragraph 30 of Plaintiff's Complaint
and therefore denies.
31. Guardian has no knowledge of paragraph 31 of Plaintiffs Complaint
and therefore denies.
32. Guardian has no knowledge of paragraph 32 of Plaintiffs Complaint
and therefore denies.
COUNT II
33. Guardian has no knowledge of paragraph 33 of Plaintiff's Complaint
and therefore denies
34. Guardian has no knowledge of paragraph 34 of Plaintiffs Complaint
and therefore denies.
35. Guardian has no knowledge of paragraph 35 of Plaintiff's Complaint
and therefore denies.
36. Guardian has no knowledge of paragraph 36 of Plaintiff's Complaint
and therefore denies.
37. Guardian has no knowledge of paragraph 37 of Plaintiffs Complaint
and therefore denies.
38. Guardian has no knowledge of paragraph 38 of Plaintiff's Complaint
and therefore denies.
39. Guardian has no knowledge of paragraph 39 of Plaintiffs Complaint
and therefore denies.
40. Guardian has no knowledge of paragraph 40 of Plaintiff's Complaint
and therefore denies.
41. Guardian has no knowledge of paragraph 41 of Plaintiffs Complaint
and therefore denies.
42. Guardian has no knowledge of paragraph 42 of Plaintiffs Complaint
and therefore denies.
43. Guardian has no knowledge of paragraph 43 of Plaintiffs Complaint
and therefore denies.
44, Guardian has no knowledge of paragraph 44 of Plaintiff's Complaint
and therefore denies.
45. Guardian has no knowledge of paragraph 45 of Plaintiff's Complaint
and therefore denies.
46. Guardian has no knowledge of paragraph 46 of Plaintiffs Complaint
and therefore denies.
47. Guardian has no knowledge of paragraph 47 of Plaintiffs Complaint
and therefore denies.
COUNT Ill
48. Guardian has no knowledge of paragraph 48 of Plaintiffs Complaint
and therefore denies.
49. Guardian has no knowledge of paragraph 49 of Plaintiffs Complaint
and therefore denies.
50. Guardian has no knowledge of paragraph 50 of Plaintiff's Complaint
and therefore denies.
51. Guardian has no knowledge of paragraph 51 of Plaintiff's Complaint
and therefore denies.
52. Guardian has no knowledge of paragraph 52 of Plaintiff's Complaint
and therefore denies.
53. Guardian has no knowledge of paragraph 53 of Plaintiffs Complaint
and therefore denies.
54. Guardian has no knowledge of paragraph 54 of Plaintiff's Complaint
and therefore denies.
55. Guardian has no knowledge of paragraph 55 of Plaintiffs Complaint
and therefore denies.
56. Guardian has no knowledge of paragraph 56 of Plaintiff's Complaint
and therefore denies.
57. Guardian has no knowledge of paragraph 57 of Plaintiffs Complaint
and therefore denies
58. In representing the Defendant MARIA GWIZDZ; MARIA GWIZDZ,
AS SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ INTER VIVOS
TRUST DATED DECEMBER 21, 2017 AND MARIA GWIZDZ, AS TRUSTEE
OF THE MARIA GWIZDZ LIVING TRUST U/A DATED DECEMBER 21, 2017; if
any, in this case as Guardian Ad Litem, Administrator Ad Litem and Attorney Ad
Litem | have expended a total of three (3) hours of professional time at $250.00
per hour, for which | respectfully request the court award me the sum of $750.00
as fees for said representation.
59. That the undersigned counsel reserves the right to file an Amended
Answer to assert any Affirmative Defenses he may have based upon any new
matters relative to the above-styled cause of action that may not have been
known to him at the time this Answer was filed.
AFFIRMATIVE DEFENSE
60. No deficiency judgment can be entered against the Unknown
Defendants since they were not personally served with process.
WHEREFORE, submits the interest of said Defendant, MARIA GWIZDZ;
MARIA GWIZDZ, AS SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ
INTER VIVOS TRUST DATED DECEMBER 21, 2017 AND MARIA GWIZDZ,
AS TRUSTEE OF THE MARIA GWIZDZ LIVING TRUST U/A DATED
DECEMBER 21, 2017; if any, and all persons having any interest in the land
described in the complaint filed herein, to the protection of the court.
GoETz & GOETZ
ATTORNEYS Law
By:
JAMES ‘GOETZ,
Florid bar No: 1538
infoG@ tzlegal.com
GREGO! W. Goetz, Esq. [ ]
Florida bar No: 46128
goetzg@goetzlegal.com
Guardian Ad Litem, Administrator
Ad Litem and Attorney Ad Litem
33 Barkley Circle, Suite 100
Fort Myers, FL 33907
(239) 936-2841, telephone
(239) 936-4197, facsimile
CERTIFICATION
| HEREBY CERTIFY that a copy of the above and foregoing has been
furnished via regular U.S. Mail to the individual(s) listed below who do not have a
primary e-mail address, all others have been sent and electronic e-mail on this
March 25, 2022.
Goetz & GOETZ
ATTORNEYS AT LAW
By:
JA L. Goetz, Esq. [X]
Flori bar No: 153865
info@goetzlegal.com
Grecory W. Goetz, Esq. [ ]
Florida bar No: 46128
goetzg@goetzlegal.com
Guardian Ad Litem, Administrator
Ad Litem and Attorney Ad Litem
33 Barkley Circle, Suite 100
Fort Myers, FL 33907
(239) 936-2841, telephone
GASKILL LAW FIRM
1800 Second Street, Ste 882
Sarasota, FL 34236
laura@gaskillpa.com
Preview
Filing # 146431402 E-Filed 03/25/2022 12:12:26 PM IN THE COUNTY COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION LOUIS ANTHONY WASYLIK, AS TRUSTEE OF THE LOUIS ANTHONY WASYLIK REVOCABLE TRUST DATED MAY 23, 2000 AND AS SUCCESSOR TRUSTEE OF THE ALICE JEAN WASYLIK REVOCABLE TRUST DATED MAY 23, 2000, Plaintiff, vs. CASE NO: 21-CA-725 SHARK’S TOOTH PROPERTIES, INC., A FLORIDA CORPORATION; et al, Defendants, ANSWER OF GUARDIAN AD LITEM, ADMINISTRATOR AD LITEM AND ATTORNEY AD LITEM COMES NOW, JAMES L. GOETZ, after having been appointed Guardian Ad Litem, Administrator Ad Litem and Attorney Ad Litem (hereafter referred to as Guardian) to represent Defendant, MARIA GWIZDZ; MARIA GWIZDZ, AS SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ INTER VIVOS TRUST DATED DECEMBER 21, 2017 AND MARIA GWIZDZ, AS TRUSTEE OF THE MARIA GWIZDZ LIVING TRUST U/A DATED DECEMBER 21, 2017; if any, and determining elsewhere to the best of his ability the facts in this cause, answers as follows: 4 Guardian admits to paragraph 1 of Plaintiffs Complaint for jurisdictional purposes only. 2. Guardian has no knowledge of paragraph 2 of Plaintiff's Complaint and therefore denies 3. Guardian has no knowledge of paragraph 3 of Plaintiff's Complaint and therefore denies 4. Guardian has no knowledge of paragraph 4 of Plaintiffs Complaint and therefore denies. 5. Guardian has no knowledge of paragraph 5 of Plaintiffs Complaint and therefore denies. 6. Guardian has no knowledge of paragraph 6 of Plaintiff's Complaint and therefore denies. 7. Guardian has no knowledge of paragraph 7 of Plaintiff's Complaint and therefore denies. 8. Guardian has no knowledge of paragraph 8 of Plaintiff's Complaint and therefore denies. 9. Guardian has no knowledge of paragraph 9 of Plaintiffs Complaint and therefore denies. 10. Guardian has no knowledge of paragraph 10 of Plaintiffs Complaint and therefore denies. 11. Guardian has no knowledge of paragraph 11 of Plaintiffs Complaint and therefore denies. 12. Guardian has no knowledge of paragraph 12 of Plaintiff's Complaint and therefore denies. 13. Guardian has no knowledge of paragraph 13 of Plaintiff's Complaint and therefore denies 14. Guardian has no knowledge of paragraph 14 of Plaintiffs Complaint and therefore denies. 15. Guardian has no knowledge of paragraph 15 of Plaintiffs Complaint and therefore denies. 16. Guardian has no knowledge of paragraph 16 of Plaintiffs Complaint and therefore denies. 17. Guardian has no knowledge of paragraph 17 of Plaintiff's Complaint and therefore denies. 18. Guardian has no knowledge of paragraph 18 of Plaintiff's Complaint and therefore denies. 19. Guardian has no knowledge of paragraph 19 of Plaintiff's Complaint and therefore denies. 20. Guardian has no knowledge of paragraph 20 of Plaintiff's Complaint and therefore denies. 21. Guardian has no knowledge of paragraph 21 of Plaintiff's Complaint and therefore denies. 22, Guardian has no knowledge of paragraph 22 of Plaintiffs Complaint and therefore denies. 23. Guardian has no knowledge of paragraph 23 of Plaintiffs Complaint and therefore denies 24. Guardian has no knowledge of paragraph 24 of Plaintiffs Complaint and therefore denies. 25. Guardian has no knowledge of paragraph 25 of Plaintiff's Complaint and therefore denies. 26. Guardian has no knowledge of paragraph 26 of Plaintiffs Complaint and therefore denies. 27. Guardian has no knowledge of paragraph 27 of Plaintiffs Complaint and therefore denies. 28. Guardian has no knowledge of paragraph 28 of Plaintiff's Complaint and therefore denies. 29. Guardian has no knowledge of paragraph 29 of Plaintiff's Complaint and therefore denies. 30. Guardian has no knowledge of paragraph 30 of Plaintiff's Complaint and therefore denies. 31. Guardian has no knowledge of paragraph 31 of Plaintiffs Complaint and therefore denies. 32. Guardian has no knowledge of paragraph 32 of Plaintiffs Complaint and therefore denies. COUNT II 33. Guardian has no knowledge of paragraph 33 of Plaintiff's Complaint and therefore denies 34. Guardian has no knowledge of paragraph 34 of Plaintiffs Complaint and therefore denies. 35. Guardian has no knowledge of paragraph 35 of Plaintiff's Complaint and therefore denies. 36. Guardian has no knowledge of paragraph 36 of Plaintiff's Complaint and therefore denies. 37. Guardian has no knowledge of paragraph 37 of Plaintiffs Complaint and therefore denies. 38. Guardian has no knowledge of paragraph 38 of Plaintiff's Complaint and therefore denies. 39. Guardian has no knowledge of paragraph 39 of Plaintiffs Complaint and therefore denies. 40. Guardian has no knowledge of paragraph 40 of Plaintiff's Complaint and therefore denies. 41. Guardian has no knowledge of paragraph 41 of Plaintiffs Complaint and therefore denies. 42. Guardian has no knowledge of paragraph 42 of Plaintiffs Complaint and therefore denies. 43. Guardian has no knowledge of paragraph 43 of Plaintiffs Complaint and therefore denies. 44, Guardian has no knowledge of paragraph 44 of Plaintiff's Complaint and therefore denies. 45. Guardian has no knowledge of paragraph 45 of Plaintiff's Complaint and therefore denies. 46. Guardian has no knowledge of paragraph 46 of Plaintiffs Complaint and therefore denies. 47. Guardian has no knowledge of paragraph 47 of Plaintiffs Complaint and therefore denies. COUNT Ill 48. Guardian has no knowledge of paragraph 48 of Plaintiffs Complaint and therefore denies. 49. Guardian has no knowledge of paragraph 49 of Plaintiffs Complaint and therefore denies. 50. Guardian has no knowledge of paragraph 50 of Plaintiff's Complaint and therefore denies. 51. Guardian has no knowledge of paragraph 51 of Plaintiff's Complaint and therefore denies. 52. Guardian has no knowledge of paragraph 52 of Plaintiff's Complaint and therefore denies. 53. Guardian has no knowledge of paragraph 53 of Plaintiffs Complaint and therefore denies. 54. Guardian has no knowledge of paragraph 54 of Plaintiff's Complaint and therefore denies. 55. Guardian has no knowledge of paragraph 55 of Plaintiffs Complaint and therefore denies. 56. Guardian has no knowledge of paragraph 56 of Plaintiff's Complaint and therefore denies. 57. Guardian has no knowledge of paragraph 57 of Plaintiffs Complaint and therefore denies 58. In representing the Defendant MARIA GWIZDZ; MARIA GWIZDZ, AS SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ INTER VIVOS TRUST DATED DECEMBER 21, 2017 AND MARIA GWIZDZ, AS TRUSTEE OF THE MARIA GWIZDZ LIVING TRUST U/A DATED DECEMBER 21, 2017; if any, in this case as Guardian Ad Litem, Administrator Ad Litem and Attorney Ad Litem | have expended a total of three (3) hours of professional time at $250.00 per hour, for which | respectfully request the court award me the sum of $750.00 as fees for said representation. 59. That the undersigned counsel reserves the right to file an Amended Answer to assert any Affirmative Defenses he may have based upon any new matters relative to the above-styled cause of action that may not have been known to him at the time this Answer was filed. AFFIRMATIVE DEFENSE 60. No deficiency judgment can be entered against the Unknown Defendants since they were not personally served with process. WHEREFORE, submits the interest of said Defendant, MARIA GWIZDZ; MARIA GWIZDZ, AS SUCCESSOR TRUSTEE OF THE STANLEY GWIZDZ INTER VIVOS TRUST DATED DECEMBER 21, 2017 AND MARIA GWIZDZ, AS TRUSTEE OF THE MARIA GWIZDZ LIVING TRUST U/A DATED DECEMBER 21, 2017; if any, and all persons having any interest in the land described in the complaint filed herein, to the protection of the court. GoETz & GOETZ ATTORNEYS Law By: JAMES ‘GOETZ, Florid bar No: 1538 infoG@ tzlegal.com GREGO! W. Goetz, Esq. [ ] Florida bar No: 46128 goetzg@goetzlegal.com Guardian Ad Litem, Administrator Ad Litem and Attorney Ad Litem 33 Barkley Circle, Suite 100 Fort Myers, FL 33907 (239) 936-2841, telephone (239) 936-4197, facsimile CERTIFICATION | HEREBY CERTIFY that a copy of the above and foregoing has been furnished via regular U.S. Mail to the individual(s) listed below who do not have a primary e-mail address, all others have been sent and electronic e-mail on this March 25, 2022. Goetz & GOETZ ATTORNEYS AT LAW By: JA L. Goetz, Esq. [X] Flori bar No: 153865 info@goetzlegal.com Grecory W. Goetz, Esq. [ ] Florida bar No: 46128 goetzg@goetzlegal.com Guardian Ad Litem, Administrator Ad Litem and Attorney Ad Litem 33 Barkley Circle, Suite 100 Fort Myers, FL 33907 (239) 936-2841, telephone GASKILL LAW FIRM 1800 Second Street, Ste 882 Sarasota, FL 34236 laura@gaskillpa.com