Action to Quiet Title and Adverse Possession! Case No.SN 2025 CV 76

Action to Quiet Title and Adverse Possession! Case No.SN 2025 CV 76 In the District court of Shawnee County Kansas Civil Department Mikel J. Lucas, Plaintiff vs. Erica Shante Denise Abrahamson, Peter Mayo Desjardins, Tenisha Elaine Brady, and Kansas Department of Revenue, Defendants. Answer to Amend Petition to Quiet Title Comes now the defendant, State of Kansas, Department of Revenue, (hereinafter referred to by "KDOR"), by and through their counsel, Scott A.Reed and for this action alleges and states as follows: 1 Each allegation and claim of the plaintifs petition that is not specifically admitted is denied. 2 Defendant is without sufficient information to form an opinion as to the truth and accuracy of the facts and allegations contained in paragraphs 2 and 3, and therefore denies the same. 3 Defendant admits that it can be served as set forth in paragraph 1. 4. Defendant states that this vehicle is not currently titled or registered in Kansas law to have an inspection completed by the highway patrol in accordance with K.S.A 8-116a before the vehicle can be titled in Kansas. Defendant further states that the Kansas Department of revenue shall review plantiffs application for certificate of title upon successful completion of an inspection in accordance with K.S.A 8-116a. WHEREFORE, the Defendant, KDOR, prays that the plantiff be denied all of its requested relief and take nothing from this action, and prays for such other relief as the court deems equitable and appropriate. Respectfully Submitted: Scott A. Reed, #23747 Legal Services Bureau Kansas Department of Revenue Tel: (785) 296-6856 October 9 2025 LHUT0374664