ANSWER TO EVICTION COMPLAINT

mukiialice64
Complaint
February 29, 2024

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,

IN AND FOR PALM BEACH COUNTY, FLORIDA

CIVIL ACTION NO: __________

 

AVID ASSET PROPERTIES HOLYWOOD, LLC, a Florida Limited Liability Company,

Plaintiff

-against-

MATHIEU INTERNATIONAL FOUNDATION, a Florida Corporation; and GINEL REGISTRE, individually

Defendants

  

ANSWER AND GENERAL DENIAL PURSUANT TO FLA. R. CIV. P. 1.110

 

ANSWER TO EVICTION COMPLAINT

Defendant, GINEL REGISTRE answers the Complaint for Eviction filed by Plaintiff as follows:

Under and pursuant to the provisions of Fla. R. Civ. P. 1.110, the answering Defendant generally denies each and every allegation of said Complaint, and the whole thereof, and each and every allegation of each and every cause of action alleged therein, and further expressly denies that as a direct or proximate result of any acts or omissions on the part of these answering Defendant, Plaintiff herein sustained or suffered injury or damage in the amount alleged in the Complaint, or in any amount at all, or that Plaintiff has suffered injury or damage for any reason in the sums alleged in the Complaint, or in any other sum or sums, or at all.

GENERAL ALLEGATIONS

  1. Defendant denies the allegations in paragraph 1.
  2. Defendant admits the allegations in paragraph 2.
  3. Defendant admits the allegations in paragraph 3.
  4. Defendant admits the contents of paragraph 4 only to the extent that it identifies Defendant as a resident of Palm Beach County, Florida. Defendant denies the remaining assertions in the paragraph, and asserts that the Court lacks jurisdiction over the subject matter because all payments were made in full. Hence, Plaintiff has no valid cause of action.
  5. Defendant maintains that this Court has no jurisdiction over this matter since Plaintiff has raised no valid claims against Defendant.

BACKGROUND

  1. Defendant admits the contents in paragraph 6.
  2. Defendant admits the contents in paragraph 7.
  3. Defendant admits the contents in paragraph 6, and maintains that all amounts were fully paid.
  4. Defendant admits the contents in paragraph 9.

DEFAULTS

  1. Defendant denies the allegations in Paragraph 10 in its entirety.
  2. Defendant denies the allegations in Paragraph 11 in its entirety.

DEMANDS FOR CURE

  1. Defendant admits the allegations in paragraph 12.
  2. Defendant admits the allegations in paragraph 13.
  3. Defendant denies the allegations in Paragraph 14 in its entirety.
  4. Defendant denies the allegations in Paragraph 15 in its entirety.
  5. Defendant denies the allegations in Paragraph 16 in its entirety.
  6. Defendant denies the allegations in Paragraph 17 in its entirety. Defendant further asserts that Plaintiff is not entitled to any amount of money since the rent was paid in full.
  7. Defendant admits the allegations in paragraph 18.

COUNT 1

TENANT EVICTION

  1. Defendant restates and incorporates herein by this reference, each of the answers contained in Paragraphs 1 through 18
  2. Defendant denies the allegations in Paragraph 20 and maintains that Tenant has rightful possession of the property after paying the rent in full.
  3. Defendant denies the allegations in Paragraph 22 in its entirety.
  4. Defendant denies the allegations in Paragraph 23 that Plaintiff is entitled to evict Tenant.
  5. Defendant restates and incorporates herein by reference, the response in paragraph 22 above.

WHEREFORE, Defendant maintains that Plaintiff is not entitled to a writ of possession or any other relief claimed in the Complaint.

COUNT 2

BREACH OF LEASE

  1. Defendant restates and incorporates herein by this reference, each of the answers contained in Paragraphs 1 through 23
  2. Defendant denies the allegations in Paragraph 25 in its entirety.
  3. Defendant denies the allegations in Paragraph 26 in its entirety.
  4. Defendant denies the allegations in Paragraph 27 in its entirety.

WHEREFORE, Defendant maintains that Plaintiff is not entitled to any damages and/or relief claimed in the Complaint.

COUNT 3

BREACH OF GUARANTEE

  1. Defendant restates and incorporates herein by this reference, each of the answers contained in Paragraphs 1 through 27
  2. Defendant denies the allegations in Paragraph 29 in its entirety.
  3. Defendant denies the allegations in Paragraph 32 in its entirety.
  4. Defendant denies the allegations in Paragraph 31 in its entirety.
  5. Defendant denies the allegations in Paragraph 32 in its entirety.
  6. Defendant denies the allegations in Paragraph 26 in its entirety.

WHEREFORE, Defendant maintains that Plaintiff is not entitled to any damages and/or relief claimed in the Complaint. Further, having answered Plaintiff’s Complaint, Defendant respectfully request that the Court enter judgment:

  1. Dismissing Plaintiff’s Complaint with prejudice.
  2. Awarding Defendants all the costs of this action.
  3. Awarding Defendants any such further relief that this Court deems just and proper.

 

Dated: ______________

Respectfully Submitted

 

_________________________

GINEL REGISTRE

Defendant, pro se

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

CERTIFICATE OF SERVICE

I, the undersigned, hereby certifies that on __________, via United States Postal Service, First Class, postage pre-paid, that a true and complete copy of the foregoing Instrument was mailed to:

 

 

 

 

 

 

 

 

_________________________

GINEL REGISTRE

Defendant, pro se

 

 

 

 

 

 

 

 

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