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4. Venue properly lies in Indian River County, Florida pursuant to Section 47.011. <br /> Fla. Stat.,because the submerged property in litigation is located in, and the causes of action set <br /> • <br /> forth herein accrued in, Indian River County. <br /> PARTIES <br /> 5. The Board is responsible for overseeing state-owned lands and ensuring they arc <br /> managed in trust for the citizens of the State of Florida pursuant to Chapter 253 Fla. Stat., and <br /> Title 18, Florida Administrative Code("Fla. Admin. Code"). <br /> 6. The Florida Department of Environmental Protection("Department")has the duty <br /> to perform all staff duties and functions related to the administration of state lands as provided in <br /> Section 253.002, Fla. Stat. <br /> 7. Defendants are"person[s]"as defined in Section 253.04, Florida Statutes, and are <br /> subject to the provisions of Chapter 253,Florida Statutes, and Florida Administrative Code <br /> Titles 18. <br /> 8. The Scotts are individuals who operate, use,or otherwise claim an interest in two <br /> structures(hereinafter"the two structures")on and over submerged real property located in <br /> Indian River County, Florida,waterward of the ordinary high water line of Blue Cypress Lake <br /> and within the lands depicted by Indian River County Property Appraiser Parcel No: <br /> 32360000000000000003.0(hereinafter the"Property"). The Scotts are not the upland riparian <br /> • <br /> owners adjacent to the Property and the two structures. <br /> 9. Defendant Indian River County,Florida, ("The County")is a political subdivision <br /> of the State of Florida who claims an interest in the Property. <br /> COUNT I—QUIET TITLE <br /> 10. The allegations in paragraphs 1 through 9 are re-alleged and incorporated herein. <br /> Page 2 of 6 <br /> 123 <br />