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NOTICE OF ACTION
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL
CIRCUIT IN AND FOR LEE
COUNTY, FLORIDA
CIVIL ACTION
CASE NO. 18-CA-4920
TERRI R. CHADWELL and DEBORAH S. RUDDELL,
Plaintiffs, v.
TK ENTERPRISES, LLP, a Maryland limited liability partnership; and PETER J. TREPPER,
Defendants.
TO: ANY UNKNOWN HEIRS, DEVISEES OR BENEFICIARIES OF MIRIAM B. CRAWFORD, DECEASED.
YOU ARE NOTIFIED that an action to reform a deed on the following property located in Lee County, Florida:
A copy of the legal description is attached hereto as Exhibit “A”.
DESCRIPTION TO ACCOMPANY SKETCH: A PLOT OR PARCEL OF LAND TO WIT: THE S. 1/2 OF THE NW. 1/4 OF THE SE. 1/4, LYING WEST OF TELEGRAPH CREEK AND LYING SOUTH OF ROAD RIGHT OF WAY, AND LESS AND EXCEPT PARCEL STRAP NUMBER 15-43-26-00-00008.0000, LYING IN SECTION 15, TOWNSHIP 43 SOUTH, RANGE 26 EAST, PUBLIC RECORDS, LEE COUNTY, FLORIDA
** NOT A BOUNDARY SURVEY **
DESCRIPTION:
A PLOT OR PARCEL OF LAND LYING IN A PORTION OF THE SOUTH HALF (S 1/2) OF THE NORTHWEST QUARTER (NW1/4) OF THE SOUTHEAST QUARTER (SE 1/4), LYING WEST OF TELEGRAPH CREEK AND LYING SOUTH OF ROAD RIGHT OF WAY, (NORTH RIVER ROAD), ALSO KNOWN AS SR 78-S) AND LESS PARCEL STRAP NUMBER 15-43-26-00-00008.0000, LYING IN SECTION 15, TOWNSHIP 43 SOUTH, RANGE 26 EAST, PUBLIC RECORDS OF LEE COUNTY, FLORIDA, FURTHER DESCRIBED AS FOLLOWS:
COMMENCING FROM THE NORTHWEST CORNER OF GOVERNMENT LOT 2, SECTION 15, TOWNSHIP 43 SOUTH, RANGE 26 EAST LEE COUNTY, FLORIDA, BEING A CONCRETE MONUMENT, FOR A POINT OF BEGINNING; THENCE RUN N00Ëš12'53”W. TO A POINT ALONG THE SOUTH RIGHT-OF-WAY LINE OF NORTH RIVER ROAD (ALSO KNOWN AS S.R. 78-S) TO A CONCRETE MONUMENT FOR 645.08 FEET; THENCE RUN N.89Ëš59'39”E. ALONG SAID SOUTH RIGHT-OF-WAY LINE TO A CONCRETE MONUMENT FOR 147.14 FEET; THENCE RUN S.89Ëš04'14”E. ALONG SAID SOUTH RIGHT-OF-WAY LINE FOR 529.26 FEET TO A CONCRETE MONUMENT AND A POINT OF CURVATURE; THENCE RUN ALONG THE ARC OF A CURVE TO THE RIGHT FOR 60.17 FEET, SAID CURVE HAVING THE FOLLOWING ELEMENTS, A RADIUS OF 2123.59 FEET, A CENTRAL DELTA ANGLE OF 01Ëš37'25, A CHORD DISTANCE OF 60.17 FEET AND A CHORD BEARING OF S.88Ëš13'50”E. TO THE WEST LINE OF FLORIDA DEPARTMENT OF TRANSPORTATION ROADWAY SECTION 1256-150, SHEET 1, DATED 1955, TITLED: 'NORTH RIVER ROAD' (80' WIDE), THENCE RUN S.02Ëš36'20”W. ALONG THE WESTERLY LIMIT OF SAID ROADWAY SECTION FOR 15.00 FEET TO A POINT OF CUSP OF CURVATURE AND A CONCRETE MONUMNET; THENCE RUN ALONG THE ARC OF A CURVE CONCAVE TO THE SOUTH FOR 30.84 FEET, SAID CURVE HAVING THE FOLLOWING ELEMENTS, A RADIUS OF 2108.59 FEET, A CENTRAL DELTA ANGLE OF 00Ëš50'17”, A CHORD DISTANCE OF 30.84 FEET AND A CHORD THAT BEARS S.86Ëš58'31”E. TO AN IRON PIN; THENCE RUN S.03Ëš31'43”W. ALONG THE WEST LINE OF THAT CERTAIN PARCEL AS RECORDED IN OFFICIAL RECORDS BOOK 186, PAGE 244, PUBLIC RECORDS OF THE CLERK OF THE CIRCUIT COURT, LEE COUNTY, FLORIDA FOR 185.00 FEET TO A CONCRETE MONUMENT; THENCE RUN S.89Ëš17'12”E. TO A POINT ALONG THE WESTERLY NATURAL SHORELINE OF TELEGRAPH CREEK, BEING THE APPROXIMATE MEAN HIGH WATERS, FOR 150.00 FEET; THENCE RUN ALONG SAID MEAN HIGH WATERS (TELEGRAPH CREEK) THE FOLLOWING BEARING AND DISTANCES,
S.48Ëš11'53”W. 17.46 FEET, S.76Ëš04'15”W. 43.46 FEET, S.83Ëš41'39”W. 41.38 FEET, S.75Ëš58'46”W. 33.29 FEET, S. 88Ëš47'36”W. 23.65 FEET, S.57Ëš09'22”W. 86.78 FEET, THENCE RUN S.17Ëš38'29”W. TO AN INTERSECTION WITH THE END OF AND WATERS EDGE FACE OF A WOODEN BULKHEAD FOR 19.06 FEET; THENCE RUN ALONG WATERS EDGE FACE OF SAID WOODEN BULKHEAD THE FOLLOWING BEARINGS AND DISTANCES,
S.10Ëš11'31”W. 40.39 FEET, S.24Ëš48'08”W. TO AN INTERSECTION WITH THE WATERS EDGE FACE OF A CONCRETE SEAWALL AND THE END OF SAID WOODEN BULKHEAD FOR 4.58 FEET, THENCE RUN ALONG THE WATERS EDGE FACE OF SAID CONCRETE SEAWALL THE FOLLOWING BEARINGS AND DISTANCES,
S.83Ëš39'48”E. 2.81 FEET, S.00Ëš52'05”E. 15.63 FEET, S.00Ëš12'31”E. 28.81 FEET, S.04Ëš40'29”W. 13.94 FEET, S.02Ëš31'00”E. 15.16 FEET, S.10Ëš33'56”W. 18.77 FEET, N.85Ëš59'23”W. TO THE END OF SAID WATERS EDGE FACE OF CONCRETE SEAWALL TO AN INTERSECTION ALONG THE WESTERLY NATURAL SHORELINE OF TELEGRAPH CREEK, BEING THE APPROXIMATE MEAN HIGH WATERS, FOR 4.10 FEET, THENCE RUN ALONG SAID WESTERLY NATURAL SHORELINE OF SAID TELEGRAPH CREEK, BEING THE SAID APPROXIMATE MEAN HIGH WATERS THE FOLLOWING BEARING AND DISTANCES,
S.09Ëš06'13”W. 124.51 FEET, S.06Ëš51'52”W. 43.16 FEET, THENCE S.25Ëš53'13”W. TO A POINT ALONG THE SOUTH LINE OF THE AFORESAID SOUTHEAST QUARTER (SE 1/4), OF THE NORTHWEST QUARTER (NW 1/4) SECTION 15 FOR 40.75 FEET, THENCE RUN N.89Ëš19'37”W. ALONG SAID SOUTH LINE TO THE NORTHWEST CORNER SAID GOVERNMENT LOT 2, FOR 598.52 FEET TO THE POINT OF BEGINNING.
CONTAINING 454,337.81 SQUARE FEET, OR 10.43 ACRES, MORE OR LESS.
/s/ PHILLIP M. MOULD
PROFESSIONAL SURVEYOR AND MAPPER #6515 - STATE OF FLORIDA
10/31/2018
SEE SHEET 1 OF 2 FOR SKETCH TO ACCOMPANY THIS DESCRIPTION
**NOT A BOUNDARY SURVEY**
15650 N RIVER RD
HARRIS-JORGENSEN LLC
3048 DEL PRADO BLVD. SUITE 100
CAPE CORAL, FLORIDA 33904-7232
PHONE: (239) 257-2624
FAX: (239) 257-2921
EXHIBIT A
has been filed against you and you are required to serve a copy of your written defenses, if any, to it on Shannon M. Puopolo, Plantiff's attorney, of the law firm of Henderson, Franklin, Starnes & Holt, P.A., whose address is Post Office Box 280, Fort Myers, Florida 33902, on or before January 1, 2019 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 or petition.
WITNESS my hand and seal of this Court on the 21 day of Nov, 2018.
LINDA DOGGETT
Clerk of Court
(Seal) By: K Hammond
Deputy Clerk
Shannon M. Puopolo
Plaintiff's attorney
Henderson, Franklin,
Starnes & Holt, P.A.
Post Office Box 280
Fort Myers, Florida 33902
Nov. 30; Dec. 7, 14, 21, 2018 18-04280L