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PLAINTIFF'S NOTICE OF ACTION
FOR CONSTRUCTIVE SERVICE -
PROPERTY
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA
CIVIL DIVISION
Case No.: 23-007246-CI
TIMOTHY R. RANNEY, an
individual; and JANNA P. RANNEY, an individual,
Plaintiffs, v.
THE UNKNOWN HEIRS OF SARAH C. BETHELL;
CHRISTOPHER KELLER, an
individual; and CITY OF ST.
PETERSBURG, a municipality
Defendants.
DEFENDANTS, THE UNKNOWN HEIRS OF SARAH C. BETHELL, ARE NOTIFIED that an action to quiet title for the following property in Pinellas County, Florida:
COMMENCE AT THE WESTERNMOST CORNER OF LOT 3, DRIFTWOOD 2ND ADDITION, AS SHOWN ON THE PLAT THEREOF RECORDED IN PLAT BOOK 22, PAGE 29, PUBLIC RECORDS OF PINELLAS COUNTY, FLORIDA; THENCE S34º48'48”E, ALONG THE NORTHEASTERLY RIGHT-OF-WAY LINE OF WARD AVENUE S., AS SHOWN ON SAID PLAT OF DRIFTWOOD 2ND ADDITION, NOW KNOWN AS DRIFTWOOD ROAD SOUTH, A DISTANCE OF 132.18 FEET TO THE POINT OF BEGINNING; THENCE CONTINUE S34º48'48”E, ALONG SAID NORTHEASTERLY RIGHT-OF-WAY LINE, A DISTANCE OF 76.03 FEET, MORE OR LESS, TO THE WATERS OF BIG BAYOU; THENCE MEANDER SOUTHWESTERLY ALONG THE WATERS OF BIG BAYOU TO A POINT ON THE SOUTHWESTERLY RIGHT-OF-WAY LINE OF SAID WARD AVENUE S.; THENCE N34º48'48”W, ALONG SAID SOUTHWESTERLY RIGHT-OF-WAY LINE, A DISTANCE OF 69.10 FEET, MORE OR LESS; THENCE N55º11'12”E, A DISTANCE OF 40.00 FEET TO POINT OF BEGINNING.
CONTAINING 2,903 SQUARE FEET (0.067 ACRE), MORE OR LESS
has been filed against you and you are required to serve a copy of your written defenses, if any, to it on Tyler A. Hayden, the Plaintiffs' attorney, whose address is 150 2nd Avenue North, Suite 1510, St. Petersburg, FL 33701, on or before September 15, 2023, and file the original with the clerk of this court either before service on the Plaintiffs' attorney or immediately thereafter; otherwise a default will be entered against you for the relief demanded in the complaint.
“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 the Human Rights Office, 400 S. Ft. Harrison Ave., Ste. 300, Clearwater, FL 33756, (727) 464-4062 (V/TDD) 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.”
DATED on 8/10, 2023.
KEN BURKE
Clerk of the Circuit Court
and Comptroller
315 Court Street Clearwater,
Pinellas County, FL 33756-5165
CLERK OF COURT
By: /s/ Thomas Smith
Deputy Clerk
/s/ Tyler A. Hayden
Tyler A. Hayden
Florida Bar No.: 095205
[email protected]
Michael J. Labbee
Florida Bar No.: 106058
[email protected]
PHILLIPS, HAYDEN & LABBEE, LLP
150 2nd Avenue North, Suite 1510
St. Petersburg, FL 33701
Telephone: (727) 300-1399
Facsimile: (727) 300-1389
Counsel for Plaintiffs
Aug. 18, 25; Sept. 1, 8, 2023 23-03531N