COMPLAINT TO QUIET TAX TITLE

    409

    IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT,
    IN AND FOR HERNANDO COUNTY, FLORIDA

    West Florida Properties
    Plaintiff,

    vs.

    Anthony Camodeca
    Betty Camodeca,
    Defendant(s).

    COMPLAINT TO QUIET TAX TITLE

    Plaintiff West Florida Properties, files this complaint to quiet title against the defendant(s), Anthony Camodeca and Betty Camodeca

    1. This is an action to quiet title to certain real property situated in Hernando County Florida, filed pursuant to F.S. 65.081. Alternatively, in the event that plaintiff’s tax deed title is determined invalid as to defendant (or any of them), this is also an action to foreclose a statutory lien for such invalidated tax deed pursuant to the provisions of F.S. 197.602.
    2. Plaintiff is the owner of in fee simple of the following described land in Hernando County, Florida:
    a. Ridge Manor Estate Unit 2 BLK 83 Lot 1
    b. Parcel ID number: R36 122 21 0870 0830 0010
    3. Plaintiff deraigns title to the land as follows:
    a. On February 1, 2017, the Plaintiff purchased the above property at a tax deed sale in Hernando County, Florida. A copy of the tax deed is attached and marked Plaintiff’s exhibit A.
    4. At the time the Plaintiff acquired title by tax deed, record title was in defendant(s), Anthony and Betty Camodeca, by virtue of a certain tax deed dated September 4, 2009 and recorded on September 4, 2009 in Official Record Book 2681, Page 1704, of the Public Records of Hernando County, Florida. A copy of the tax deed is attached and marked Plaintiff’s Exhibit B.
    5. Any and all claims, rights, title, or interest of defendant to the real property described herein had been extinguished by the tax deed described herein; and Plaintiff is the owner to the real property and the legal and equitable owner in fee simple, and is entitled to have its title to the real property quieted and confirmed by the court under the provisions of F.S. 65.081.
    6. Pleading in the alternative, Plaintiff requests that if this court determines that the tax deed title issued to the Plaintiff is void as to any of the Defendants, the court determine in its final judgment that Plaintiff holds a valid lien on the subject real property for the amount of money paid by Plaintiff for the tax deed ($3,800), together with interest thereon at 12% per annum from the date of purchase, February 1, 2017, and the costs of this action, including attorney’s fees.

    WHEREFORE, the Plaintiff demands the following
    A. That upon final hearing, the fee simple title to the above-described property be adjudicated owned by the Plaintiff.
    B. The Defendant(s) be required to set forth the nature of its claim to the above-described real property and that all adverse claims by Defendant be determined by judgment of this court to be null and void against the Plaintiff.
    C. That all right, title, and interest Defendant be forever quieted and ownership confirmed to the Plaintiff.
    D. That in the event the tax deed title of Plaintiff be invalidated, Plaintiff’s statutory lien for the amount paid for the tax deed together with interest from the date the tax deed was purchased, costs, and attorney’s fees be foreclosed and that the subject real property be sold by the clerk of courts to satisfy said lien.

    Attorney for Nelsestuen Bayle Law Firm

    Eric Nelsestuen
    P.O. 703
    Lutz, FL 33548
    813-997-1959/352-263-7742
    [email protected]
    [email protected]
    Florida Bar Number: 127178

    (08/11/2017)