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NOTICE TO SHOW CAUSE
AND NOTICE OF SUIT
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PASCO COUNTY, FLORIDA
Case No.: 2019-CA-002788 ES
Parcel 106
STATE OF FLORIDA DEPARTMENT
OF TRANSPORTATION,
Petitioner, -vs-
ORIENT ROAD BAIL BONDS, INC.,
A Florida Corporation' POONG JIN BRADLEY; JOSEPH M. FERNANDEZ, III d/b/a Across the Street Bail Bonds; FRANCES C. FERNANDEZ, d/b/a Frances Bail Bonds; PASCO COUNTY TAX COLLECTOR, Mike Fasano or his designee; and ALL UNKNOWN PARTIES THAT MAY HAVE AN INTEREST IN PARCEL 106,
Defendants.
STATE OF FLORIDA TO:
Poong Jin Bradley
15 San Pablo Court
Novato, CA 94949-8272
Orient Road Bail Bonds, Inc., a Florida corporation
Serve: Stephen J. Stanley, Esq.,
as attorney
412 E. Madison Street - Suite 1100
Tampa, FL 33602
Joseph M. Fernandez, III,
d/b/a Across the Street Bail Bonds
Serve: Stephen J. Stanley, Esq.,
as attorney
412 E. Madison Street - Suite 1100
Tampa, FL 33602
Frances C. Fernandez,
d/b/a Frances Bail Bonds
Serve: Stephen J. Stanley, Esq.,
as attorney
412 E. Madison Street - Suite 1100
Tampa, FL 33602
Pasco County Tax Collector
Serve: Mike Fasano or his designee
E. Pasco Government Center 14236 6th Street, Room 100
Dade City, FL 33523-3411
All unknown parties that may have an interest in Parcel 106
Serve: Via Publication
To all said defendants who are living and all defendants who are deceased, if any, and the unknown spouse, heirs, devisees, grantees, creditors, lienors, or other parties claiming by, through, under, or against any such defendant or defendants, if alive, and, if dead, their unknown spouse, heirs, devisees, legatees, grantees, creditors, lienors, or other parties claiming by, through, under, or against any such deceased defendant or defendants, and all other parties having or claiming to have any right, title, or interest in and to the property described in the Petition, to wit:
WPIS 2563242 STATE ROAD 45 PASCO COUNTY DESCRIPTION
PARCEL 106 FEE SIMPLE RIGHT OF WAY
Those portions of Lots 25 and 26 of LAND O' LAKES ADDITION as recorded in Plat Book 4, Page 59 of the Public Records of Pasco County, Florida, and lying in the Northwest 1/4 of Section 22, Township 25 South, Range 18 East, Pasco County, Florida, being more particularly described as follows:
COMMENCE at a Parker-Kalon nail and disk stamped “LS 3875” marking the North 1/4 corner of Section 22, Township 25 South, Range 18 East, Pasco County, Florida; thence along the east line of the Northwest 1/4 of said Section 22, South 00°22'26” West, a distance of 1,996.65 feet to a point on the survey line for State Road No. 45, as shown on Florida Department of Transportation Right of Way Map Section 14010-XXXX, Financial Project No. 256324 2; thence along said survey line, North 31°24'12” West, a distance of 1,678.04 feet; thence departing said survey line, South 58°36'45” West, a distance of 87.50 feet to the point of intersection with the existing westerly right of way line of said State Road No. 45 per Official Records Book 8824, Page 2894 of the Public Records of Pasco County, Florida, and the northerly line of Lot 25 of Land O' Lakes Addition as recorded in Plat Book 4, Page 59 of the Public Records of Pasco County, Florida, and the POINT OF BEGINNING; thence departing said northerly lot line and along said existing westerly right of way line, South 31°24'12” East, a distance of 200.06 feet to the intersection with the southerly line of Lot 26; thence departing said existing westerly right of way line and along said southerly lot line, South 58°36'40” West, a distance of 442.63 feet to the southwest corner of said Lot 26; thence along the westerly line of said Lots 25 and 26, North 31°24'04” West, a distance of 200.07 feet to the northwest corner of said Lot 25; thence along the northerly line of said Lot 25, North 58°36'45” East, a distance of 442.63 feet to the POINT OF BEGINNING
Containing 2.033 acres, more or less.
You are each notified that the Petitioner filed its sworn Petition and its Declaration of Taking in this Court against you as defendants, seeking to condemn by eminent domain proceedings the above-described property located in the State of Florida, County of Pasco You are further notified that the Petitioner will apply to the Honorable Gregory Groger of the Judges of this Court on the 28th day of January, 2020, at 2:30pm, at the Robert D Sumner Judicial Center, 38053 Live Oak Av., Room 106A, Dade City, Florida 33523, for an Order of Taking in this cause. All respondents to this suit may request a hearing at the time and place designated and be heard. Any respondent failing to file a request for hearing shall waive any right to object to the Order of Taking.
AND
Each defendant is hereby required to serve written defenses, if any, and request a hearing, if desired, to said Petition on:
State of Florida,
Department of Transportation
11201 N. McKinley Drive
Tampa, Florida 33612
c/o Rodney Wade
(813) 975-6485
Florida Bar No.: 0374091
[email protected]
[email protected]
on or before December 27, 2019, and to file the originals with the Clerk of this Court on that date, to show cause what right, title, interest, or lien you or any of you have in and to the property described in the Petition and to show cause, if any you have, why the property should not be condemned for the uses and purposes set forth in the Petition.
If you fail to answer, a default may be entered against you for the relief demanded in the Petition. If you fail to request a hearing on the Petition for Order of Taking you shall waive any right to object to said Order of Taking.
If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Public Information Dept., Pasco County Government Center, 7530 Little Rd., New Port Richey, FL 34654; (727) 847-8110 (V) for proceedings in New Port Richey; (352) 521-4274, ext. 8110 (V) for proceedings in Dade City at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711.
WITNESS MY HAND AND SEAL of said Court on the 4th day of Nov, 2019.
NIKKI ALVAREZ-SOWLES, ESQ.
CLERK OF THE CIRCUIT COURT
By: /s/ Patricia Duby
Deputy Clerk
November 15, 22, 2019 19-02501P