On November 12, 2018 a
ANSWER/COUNTER AND AFFIRMATIVE DEFENSES TO PLAINTIFFS AMENDED COMPLAINT
was filed
involving a dispute between
Mattox, Marie A,
and
Kevin Crews In His Official Ca,
Washington County Florida,
for OTHER
in the District Court of Washington County.
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Filing # 82021894 E-Filed 12/12/2018 03:05:34 PM
IN THE CIRCUIT COURT OF THE FOURTEENTH
JUDICIAL CIRCUIT, IN AND FOR
WASHINGTON COUNTY, FLORIDA
MARIE A. MATTOX, P.A.
Petitioner,
v. CASE NO. 2018-CA-125
KEVIN CREWS, in his official capacity as the
Sheriff of Washington County, Florida,
and Washington County, Florida,
ANSWER AND AFFIRMATIVE DEFENSES
TO PLAINTIFF’S AMENDED COMPLAINT
Respondent, KEVIN CREWS, in his official capacity as SHERIFF of WASHINGTON
COUNTY, FLORIDA and Washington County, by and through undersigned counsel,
responds to the Petitioner's Complaint as follows
1. Admit action deny liability.
2. Admit.
3. Admit.
4. Admit.
5. Admit.
6. Admit first through third sentences. Without knowledge, therefore Denied to
remaining allegations.
7. Admit.
8. Admit.
1
Electronically Filed Washington Case # 18000125CAAXMX 12/12/2018 02:05:34 PM10.
11.
12.
13.
14,
15.
16.
17.
18.
19.
20.
21.
22.
23.
1)
Admit.
Without knowledge, therefore Denied.
Admit.
Admit.
Denied.
Denied.
Admit.
Denied.
Admit.
Denied
Denied,
Denied.
Denied.
Denied.
Denied.
AFFIRMATIVE DEFENSES
Plaintiff failed to give five (5) days written notice to Defendant Washington
County’s records custodian identifying the public records request to filing the lawsuit.
Respectfully submitted on December 12, 2018.
/s/ R.W. Evans
R. W. Evans
Florida Bar No. 0198862
revans@anblaw.comALLEN, NORTON & BLUE, P.A.
906 N. Monroe Street
Tallahassee, FL 32303
(850) 561-3503
MATT FUQUA
mfugua@fme. legal
Fuqua & Milton, P.A.
PO Box 1508
Marianna, FL 32447
Counsel for Defendant
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
on December 12, 2018 via the Florida E-Filing portal which will automatically transmit a
copy to counsel of record.
/si R.W. Evans
Attorney
Document Filed Date
December 12, 2018
Case Filing Date
November 12, 2018
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Filing # 82021894 E-Filed 12/12/2018 03:05:34 PM IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, IN AND FOR WASHINGTON COUNTY, FLORIDA MARIE A. MATTOX, P.A. Petitioner, v. CASE NO. 2018-CA-125 KEVIN CREWS, in his official capacity as the Sheriff of Washington County, Florida, and Washington County, Florida, ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF’S AMENDED COMPLAINT Respondent, KEVIN CREWS, in his official capacity as SHERIFF of WASHINGTON COUNTY, FLORIDA and Washington County, by and through undersigned counsel, responds to the Petitioner's Complaint as follows 1. Admit action deny liability. 2. Admit. 3. Admit. 4. Admit. 5. Admit. 6. Admit first through third sentences. Without knowledge, therefore Denied to remaining allegations. 7. Admit. 8. Admit. 1 Electronically Filed Washington Case # 18000125CAAXMX 12/12/2018 02:05:34 PM10. 11. 12. 13. 14, 15. 16. 17. 18. 19. 20. 21. 22. 23. 1) Admit. Without knowledge, therefore Denied. Admit. Admit. Denied. Denied. Admit. Denied. Admit. Denied Denied, Denied. Denied. Denied. Denied. AFFIRMATIVE DEFENSES Plaintiff failed to give five (5) days written notice to Defendant Washington County’s records custodian identifying the public records request to filing the lawsuit. Respectfully submitted on December 12, 2018. /s/ R.W. Evans R. W. Evans Florida Bar No. 0198862 revans@anblaw.comALLEN, NORTON & BLUE, P.A. 906 N. Monroe Street Tallahassee, FL 32303 (850) 561-3503 MATT FUQUA mfugua@fme. legal Fuqua & Milton, P.A. PO Box 1508 Marianna, FL 32447 Counsel for Defendant CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished on December 12, 2018 via the Florida E-Filing portal which will automatically transmit a copy to counsel of record. /si R.W. Evans Attorney