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NOTICE OF ACTION UNDER FLORIDA STATUTE §49.08
IN THE CIRCUIT COURT
FOR THE 12TH JUDICIAL CIRCUIT,
IN AND FOR SARASOTA COUNTY,
FLORIDA
CASE NO.: 2019 CA 005961 NC
SHEA RALPH
Plaintiff, v.
PNC BANK, N.A., GLENDA C. FAIR, CYNTHIA L. FAIR, AND LAUREEN C. JONES,
Defendants.
BEFORE ME, the undersigned authority, personally appeared JAMES R. CHANDLER, III (“Affiant”), who is personally known to me, who after being duly sworn and cautioned, states that he is executing the following document and states as follows:
1. Names of known Defendants:
a. Glenda C. Fair upon whom traditional service of process has been or will be obtained.
b. Cynthia L. Fair (now deceased)
formerly residing at:
410 West Poplar
Johnson City, TN 37604
with known surviving heirs to wit:
Dale Fair (Husband)
410 West Poplar
Johnson City, TN 37604
Charlene C. Foxx (Daughter)
610 1st SW Avenue
Dickinson, ND 58601
c. Laureen C. Jones (now deceased)
1814 Cottonwood Trail
Sarasota, Florida 34232
and/or
2303 Trinidad Street
Sarasota, Florida
with known surviving heirs to wit:
Linda Alcala (Daughter)
14840 Orange Grove Avenue
Hacienda Heights, California
Cindy Neunder (Daughter)
136 Avens Drive
Nokomis, Florida 34275
d. PNC Bank, N.A. upon whom traditional service of process has been obtained.
2. The nature of the action is a proceeding to quiet title on the following described real property in Sarasota County, Florida with a street address of 4765 Riverwood Circle, Sarasota, Florida 34321 and is more particularly described as follows:
COM AT SW COR LOT 7 TH N 89-32 E 480 FT ALG S LINE FOR POB TH N 112 FT PARALLEL TO W LINE TH N 46-44 E 41.2 FT TH N 60 FT PARALLEL TO W LINE TO N LINE LOT 6 TH N 89-32 E 30.42 FT ALG N LINE TO A POINT 540.42 FT E OF SW COR OF LOT 5 TH ANGLE 50-28 TO LEFT N 39-04 E 39.1 FT TO S LINE OF 80 FT PROPOSED R/W TH S 73-21-54 E 244 FT M/L ALG R/W TO PHILLIPPI CREEK TH SELY WLY NLY LWLY & SLY TO S LINE LOT 7 TH S 89-32 W 281 FT M/L ALG S LINE TO POB, BEING PART OF LOTS 5 6 & 7, SUBJ TO UTILITY ESMT TO SARASOTA COUNTY DESC IN ORI 2005108872, AMENDED PLAT OF RIVERWOOD PARK
The Plaintiff seeks to quiet title to the subject property as relates to the failure of the named individual Defendants to properly execute and record a Satisfaction of the Mortgage they held on the property following the payment of all sums due to them on the Mortgage.
3. The Court in which this proceeding was instituted is as follows: The Circuit Court in the Twelfth Judicial Circuit in and for Sarasota County, Florida. The description of the real property proceeded against is as afore-stated.
4. The Defendants and all others claiming through them shall file written defenses with the Clerk of the Court on or before February 17, 2020 and serve a copy thereof on counsel for Plaintiff or the attorney whose name and address is as follows: James R. Chandler, III, Esq., Bender Bender & Chandler, PA., 323 10th Avenue West, Suite 301, Sarasota, Florida 34221.
DATED ON January 7, 2020.
Karen E. Rushing,
as Clerk of said Court
(Court seal) By: G. Kopinsky
as Deputy Clerk
Respectfully submitted,
/s/ James R. Chandler, III
James R. Chandler III
Bender, Bender and Chandler, P.A.
Florida Bar No. 0198145
Attorney for Petitioner
323 10th Avenue West, Suite 301
Palmetto, FL 34221
E-mail: [email protected]
Office: 941-723-3425
Jan. 17, 24, 31; Feb. 7, 2020 20-00098S