On October 15, 2019 a
Answer
was filed
involving a dispute between
First Federal Bank,
and
Dansby, Lealon M,
Freeman, Kimbraly M,
Hillary Kirkland As Personal R,
Kirkland, Franklin H,
Kirkland, Hillary,
Periko, Michelle L,
United States Of America Depar,
Unknown Heirs Beneficiaries De,
for Circuit Civil 37-D
in the District Court of Washington County.
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Filing # 98573247 E-Filed 11/07/2019 05:19:28 PM
IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT
IN AND FOR WASHINGTON COUNTY, FLORIDA
FIRST FEDERAL BANK,
Plaintiff,
Case No: 2019 CA 191
ve
HILLARY KIRKLAND, et al.,
Defendants.
ANSWER TO COMPLAINT
COMES NOW the Defendant, United States of America, through the undersigned
attorney, and in answer to the complaint states:
Count I
1. Defendant admits the allegations contained in paragraph 1.
2. Defendant does not have sufficient knowledge to respond to the allegations contained in
paragraphs 2 through 13 and therefore denies the allegations.
3. Answering the allegations contained in paragraph 14, Defendant, United States of
America on behalf of Department of Treasury — Internal Revenue Service (IRS), admits it
may have an interest in the property as set forth in said paragraph, but denies the
allegations that said interest is inferior and subordinate.
4. Defendant does not have sufficient knowledge to respond to the allegations contained in
paragraphs 15 through 21 and therefore denies the allegations.
Electronically Filed Washington Case # 19000191CAAXMX 11/07/2019 04:19:28 PMWHEREFORE, the defendant PRAYS:
A. If this court decrees that the property be sold at a foreclosure sale, this defendant’s lien(s)
be accorded its priority for payment from the proceeds of the sale in accordance to law.
B. Further, if said lien(s) is not paid, that any decree provide that the United States of America
shall have a period of one year from the sale to redeem the property or with respect to a
lien arising under the internal revenue laws, a period of 120 days. 28 U.S.C. 2410.
C. That this Defendant be granted such other and further relief as the court deems just and
proper.
Certificate of Service
On November 7th, 2019, a copy of the foregoing was electronically mailed to: Kelley L.
Church, Esq, at servicecopies@qpwblaw.com. .
LAWRENCE KEEFE
United States Attorney
s/Kathryn W._Drey
Kathryn W. Drey
Assistant United States Attorney
Florida Bar: 142492
21 East Garden Street, Suite 400
Pensacola, Florida 32502
850.444.4000
E-filing: usafln.state.court@usdoj.gov
Document Filed Date
November 07, 2019
Case Filing Date
October 15, 2019
Category
Circuit Civil 37-D
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Filing # 98573247 E-Filed 11/07/2019 05:19:28 PM IN THE CIRCUIT COURT, FOURTEENTH JUDICIAL CIRCUIT IN AND FOR WASHINGTON COUNTY, FLORIDA FIRST FEDERAL BANK, Plaintiff, Case No: 2019 CA 191 ve HILLARY KIRKLAND, et al., Defendants. ANSWER TO COMPLAINT COMES NOW the Defendant, United States of America, through the undersigned attorney, and in answer to the complaint states: Count I 1. Defendant admits the allegations contained in paragraph 1. 2. Defendant does not have sufficient knowledge to respond to the allegations contained in paragraphs 2 through 13 and therefore denies the allegations. 3. Answering the allegations contained in paragraph 14, Defendant, United States of America on behalf of Department of Treasury — Internal Revenue Service (IRS), admits it may have an interest in the property as set forth in said paragraph, but denies the allegations that said interest is inferior and subordinate. 4. Defendant does not have sufficient knowledge to respond to the allegations contained in paragraphs 15 through 21 and therefore denies the allegations. Electronically Filed Washington Case # 19000191CAAXMX 11/07/2019 04:19:28 PMWHEREFORE, the defendant PRAYS: A. If this court decrees that the property be sold at a foreclosure sale, this defendant’s lien(s) be accorded its priority for payment from the proceeds of the sale in accordance to law. B. Further, if said lien(s) is not paid, that any decree provide that the United States of America shall have a period of one year from the sale to redeem the property or with respect to a lien arising under the internal revenue laws, a period of 120 days. 28 U.S.C. 2410. C. That this Defendant be granted such other and further relief as the court deems just and proper. Certificate of Service On November 7th, 2019, a copy of the foregoing was electronically mailed to: Kelley L. Church, Esq, at servicecopies@qpwblaw.com. . LAWRENCE KEEFE United States Attorney s/Kathryn W._Drey Kathryn W. Drey Assistant United States Attorney Florida Bar: 142492 21 East Garden Street, Suite 400 Pensacola, Florida 32502 850.444.4000 E-filing: usafln.state.court@usdoj.gov