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NOTICE OF ACTION
IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
CIVIL DIVISION
Case No.: 23-CA-14772
Division: G
MELVIN S. JACOBSON, an individual,
Plaintiff, vs.
GARDEN OF MEMORIES, INC., a
Florida corporation, S.E. COMBINED SERVICES OF FLORIDA, LLC, as Florida
limited liability company doing
business under the registered fictious name Blount & Curry Funeral Home at Garden of Memories, That certain
FLORIDA TRUST settled by Robert
Jacobson, Louis Jacobson, Samuel
Jacobson and Sophia Zeitlin, through that certain Declaration of Trust dated September 19, 1969, ROSE JACOBSON, STEPHEN JACOBSON, SONYA JACOBSON, RHONDA FRAZIER, PAULA BUTLER, and LARRY BUTLER,
Defendants,
PLEASE TAKE NOTICE Melvin S. Jacobson (the “Plaintiff”), by and through his undersigned attorneys, filed his Amended Complaint (the “Complaint”) in the Thirteenth Judicial Circuit in and for Hillsborough County, Florida on July 12, 2024.
1. In the Complaint, the Plaintiff seeks relief against the unknown spouse, heirs, devisees, assignees, trustees, personal representatives and all other parties claimants an interest by, through, under or against Rose Jacobson, deceased on September 14, 2023 (cumulatively, the “Rose Jacobson Heirs”).
2. In the Complaint, the Plaintiff seeks relief against the unknown spouse, heirs, devisees, assignees, trustees, personal representatives and all other parties claimants an interest by, through, under or against Louis Jacobson, deceased July 10, 2013 (cumulatively, the “Louis Jacobson Heirs”).
3. This is an action to seeking the construction of that certain Declaration of Trust dated September 19, 1969 executed by and between Robert Jacobson, Louis Jacobson, Samuel Jacobson and Sophia Zeitlin as well as that certain Agreement between Louis Jacobson and Myrtle Hill Memorial Park, Inc. dated August 6, 1969, and for a judicial declaration or enforcement of any legal or equitable right, title, claim, lien, or interest thereunder within the jurisdiction of the Court.
4. This action is pending in the Thirteenth Judicial Circuit in and for Hillsborough County, Florida.
5. The personal property at issue in this action is “the exclusive right to internment in a plot at the Myrtle Hill Memorial Park, Inc. located in Hillsborough County, Florida containing 18 adult internment spaces” in Section 30. Of the 18 original spaces No human remains have been interned to date in spaces 1, 3, 4, 5, 6, 7 and 8 remain empty.
6. The Rose Jacobson Heirs and Louis Jacobson Heirs are required to file written defenses with the Clerk of the Court and to serve a copy within thirty (30) days after the first publication of this Notice on John W. Landkammer, Esq., Anthony & Partners, LLC, 100 S. Ashley Dr., Suite 1600, Tampa, Florida 33602, attorney for the Plaintiff.
DATED on 7/17/2024.
CINDY STUART
Clerk of the Circuit Court
Hillsborough County, Florida
Hillsborough County Courthouse
800 E. Twiggs St.
Tampa, FL 33602
(SEAL) By: /s/ Isha Tirado-Baker
Deputy Clerk
Prepared by:
JOHN W. LANDKAMMER,
ESQUIRE
Florida Bar Number: 675547
jlandkammer@
anthonyandpartners.com
Anthony & Partners, LLC
100 S. Ashley Dr., Suite 1600
Tampa, Florida 33602
Telephone: 813/273-5616
Telecopier: 813/221-4113
Attorneys for the Plaintiff
Jul. 19, 26; Aug. 2, 9, 2024 24-02231H