Lack of jurisidiction would be my choice if you have to state something specific,

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Originally Posted by kip1906

Hi AK,

Do you live/practice in Florida?

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Admitted in Alaska. Presently in Florida without means to get me and my family back. Can't practice in FL because I'm not admitted to the bar here and the cost of taking the bar exam ($2,500) is more than I have.

But enough about me. :)

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Originally Posted by kip1906

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I sold to the current owner in 2001. I paid my mortgage at closing and the new owner initiated her own new mortgage on the property. I think Scott is right on.."shotgun litigation"...

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Does look that way.

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Originally Posted by kip1906

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If there is nothing I can do to award the plaintiff his claim - there is nothing he can gain from me as a defendant. I do not own this property, nor had anything to do with it since 2001.

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Is he asking for a money judgment from you? Naturally you don't want him to get that, but as far as other relief regarding the property:
(1Reformation of Warranty Deed
2)Mortgage Foreclosure
3)Re-establishment of Note. ) you don't care, right?

So your answer should simply recite your supreme indifference to whatever the plaintiff wants regarding the property.