Item S01
IN THE COUNTY COURT OF THE 16TH
JUICIAL CIRCUIT IN AND FOR
MONROE COUNTY, FLORIDA
CASE NO: CAP-02-129
BOARD OF COUNTY COMMISSIONERS
Of Monroe County, a political subdivision of
The State of Florida,
Plaintiff,
~_n] _-
~~@l%TI~J]~~
~t MAR 1 8 2002
Vs.
KEY LARGO OCEAN RESORT CO-OP, INC.
Defendant.
/
ANSWER
COMES NOW the Defendant, KEY LARGO OCEAN RESORT CO-OP, INe.
(hereinafter referred to as KLOR), by and through its undersigned attorney and files this Answer
to the Complaint as follows:
1. The Defendant admits the allegations of paragraphs 1,2,3,4,5,6, 7, 8,9, 10, 11,
12, 13, and 14.
2. The Defendant admits the allegations of paragraph 12 as it alleges the mailing and
receipt of the Notice of Statutory Rights, but otherwise denies or accepts the offer
for the property contained therein in the amount of$10,000.00
WHEREFORE the Defendant prays:
1, The Court enter a judgment for the relief sought by Plaintiff.
2. The Court enter a judgment in favor of the Defendant for the fair market value of
the property.-
3. The Court enter a judgment in favor of Defendant for the value of all expenses
and improvements made to the property which i-s the subj~ctofthis Complaint.
S\
4. Court award the Defendant attorney's fees and costs associated with this
Complaint pursuant to FS 73.092.
5. The Court order any further relief which it deems proper.
RESPECTFULLY SUBMITTED,
~~
JOAQUIN N. FERNANDEZ, ESQ.
12405 S.W. 56 St.
Miami, FL 33175
Telephone: (305) 975-8096
Fax: (305) 220-3291
Florida Bar No: 229180
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing was furnished via
u.s. mail to Suzanne A. Hutton, Assistant County Attorney, P.O. Box 1026, Key West, FL
33041-1026, this 14th day of March, 2002.
~.~~
N. FERNANDEZ, ESQ.