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FIRST INSERTION
NOTICE OF ACTION - PROPERTY
IN THE CIRCUIT COURT
OF THE SIXTH JUDICIAL CIRCUIT STATE OF FLORIDA, IN AND FOR PASCO COUNTY
CIVIL DIVISION
Case No. 2010-CA-009053-WS/G
HAYES ROAD SAND COMPANY, LLC, and NANCY N. SKEMP, a/k/a NANCY SKEMP, as TRUSTEE OF THE CDN TRUST NUMBER TWO and as an individual, and NANCY N. SKEMP AS SUCCESSOR TRUSTEE OF THE CDN TRUST NUMBER ONE,
Plaintiffs, vs.
NANCY N. SKEMP, a/k/a
NANCY SKEMP. as Personal
Representative of the Estate of Copeland D. Newbern, Deceased, CAROLINE N. SHEPARD,
individually, and EDNA C.
NEWBERN, Deceased, and her unknown personal representatives, heirs, devisees, grantees, assignees, creditors, lienors, trustees, and all persons claiming by, through or under her, including NANCY N. SKEMP a/k/a NANCY SKEMP and CAROLINE N. SHEPARD, as Trustees of the Edna C. Newbern Revocable Trust U/A dtd 11/19/07 and individually,
Defendants.
To: Edna C. Newbern, DECEASED, and her unknown Personal Representatives, heirs, devisees, grantees, assignees, creditors, lienors, trustees, and all persons claiming by, through or under her
Residence Unknown
YOU ARE HEREBY NOTIFIED that an action to quite title, impose a constructive trust and reformation of a deed on the following property in Pasco County, Florida:
SEE EXHIBIT “A” ATTACHED HERETO
EXHIBIT A
Parcel 1 - Folio Number 36-24-17-0000-00900-0000
That part of the North 1/2 of Section 36, Township 24 South, Range 17 East lying East of Hays Road described as follows: Begin at the Northeast corner of said section 36; thence S 00º16'11”E., along the East boundary of said Section 36 (an assumed bearing), a distance of 2647.77 feet to the Southeast corner of said North 1/2 of Section 36; thence S 89º42'26”W. along the South boundary of said North 1/2 of Section 36, a distance of 2644.70 feet to the Southwest corner of the Northeast 1/4; thence continue along the South Boundary of said North 1/2 of Section 36, S 89º 42'09” W., a distance of 977.57 feet to the Easterly right of way line of Hays Road and a point of curvature ; thence along said right of way line 330.37 feet on an arc of a curve to the left , with a radius of 1430 feet, subtended by a chord 329.64 feet, chord bearing N 06º18'22” E., to a point of tangency; thence continued along said right of way line, N 00º18'45” W., a distance of 1710.59 feet to a point of curvature; thence continue along side right of way line, 210.66 feet on an arc of a curve to the left, with a radius of 730.00 feet, subtended by a chord of 209.93 feet, chord bearing N 08º34'47” W., thence leaving said right of way line N 89º38'45” E., a distance of 339.26 feet; thence N. 00º21'14” W., a distance of 400.00 feet to a point on the North boundary of said Section 36; a distance of 635.26 feet to the Northwest corner of the Northeast 1/4 of said Section 36; thence N. 89º38'46” E, along the North boundary of said Section 36; thence continue along the North boundary of said section 36, N 89º41'05” E., a distance of 2642.21 feet to the point of Beginning.
AND
The North 1/2 of the Northeast 1/2 of the Southeast 1/2, all being in Section 36, Township 24 South, Rage 17 East Pasco County, Florida.
AND
Parcel 2 - Folio Number 36-24-17-0000-00900-0020
A tract of land being in Section 36, Township 24 South, Range 17 East Pasco County, Florida described as follows: Commence at the Northwest corner of the Northeast 1/4 of said Section 36; thence S 89º38'46” W. along the North boundary of said Section 36, a distance of 635.26 feet for a Point of Beginning; thence S 00º21'14” E., a distance of 400.00 feet; thence S 89º38'46” W., a distance of 339.26 feet to a point on the Easterly right of way line of Hays Road and a point of curvature; thence along said Easterly right of way line 181.48 feet on an arc of a curve to the left, with a radius of 730.00 feet, subtended by a chord of 181.01 feet, chord bearing N 23º58'08” W. to a point of tangency; thence continue along said right of way, N 31º05'27” W., a distance of 272.42 feet to a point on the North boundary of said Section 36; thence N 89º38'46” E., a distance of 551.00 feet to the Point of Beginning.
has been filed against you and you are required to serve a copy of your written defenses, if any, on the plaintiff's attorney, whose name and address is:
Michael D. LaBarbera
LaBarbera and Campbell
1907 West Kennedy Boulevard
Tampa, FL 33606
(813) 251-1940
on or before May 14, 2012, and file the original with the clerk of this court either before service on plaintiff's attorney or immediately thereafter; otherwise, a default will be entered against you for the relief demanded in the complaint.
In accordance with the Americans With Disabilities Act, persons with disabilities needing a special accommodation to participate in this proceeding should contact Dade City (352) 521-4274, Ext. 8110; New Port Richey (727) 847-8100; TDD 1-800-955-8771 via Florida Relay Service; no later than seven (7) days prior to any proceeding.
Witness my hand and seal of said Court on this April 13, 2012.
PAULA S. O'NEIL,
Clerk & Comptroller
Clerk of Circuit Court
(SEAL) By: LeAnn A. Jones
Deputy Clerk
Michael D. LaBarbera
LaBarbera and Campbell
1907 West Kennedy Boulevard
Tampa, FL 33606
Telephone (813) 251-1940
April 13, 20, 27; May 4, 2012 12-1149P