MOTION TO AMEND ( V )

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On April 8, 2020 an other complaint case was filed by Perez, Joseph, and Perez, Nyobi, represented by Forkey, Russell Lee, against Camacho, Eusebio Jr, represented by Manie, Andrew John, in the jurisdiction of St. Lucie County. Judge BUCHANAN, LAURIE E presiding.

                        
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                          Filing # 115326143 E-Filed 10/21/2020 08:49:30 AM

IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR ST. LUCIE COUNTY, FLORIDA

JOSEPH PEREZ and NYOBI PEREZ,

Plaintiff, CASE NO: 2020-CA-000574
v.

EUSEBIO CAMACHO, JR.,

Defendant.
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MOTION TO AMEND ANSWER AND AFFIRMATIVE DEFENSES
AND INCLUDE COUNTERCLAIM

COMES NOW, the Defendant, Eusebio Camacho, Jr. (hereinafter “Defendant”), by and
through undersigned counsel and in accordance with Rule 1.190, Florida Rules of Civil Procedure,
and moves the Court for leave to file an Amended Answer and Affirmative Defenses to include
counter claims in response to the Plaintiffs’, Joseph Perez and Nyobi Perez (hereinafter

“Plaintiff”), Complaint, and in support thereof states the following:

FACTUAL AND PROCEDURAL BACKGROUND

1. In 2010, the Defendant and Evette Santiago-Camacho divorced.

2. The Defendant and Mrs. Camacho had several children, which included the Plaintiff, Nyobi
Perez.

3. As a part of the marital settlement …