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NOTICE OF ACTION
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT
IN AND FOR PASCO COUNTY, FLORIDA
CIVIL DIVISION
Case No.:
2024CA000035CAAXES
SAV PROPERTY HOLDINGS LLC,
a New Jersey limited liability company
Plaintiff, v.
O.L. RAY; E. FRED HERSCHBACH; JOHN K. KEYES; REUBEN BROOKS; DR. A.H. MCCOY; MICHAEL P. METCALF; EMMETTE F. GATHRIGHT; ROBERT A. HERSCHBACH; RUDMAN RESOURCES, INC., a Texas corporation; J. COLLINS WOHNER; ARDEN A. ANDERSON; PAT R. JEFFREYS, TRUSTEE; HAYWOOD HANNA, JR.; ROBERT S. DIX; E.G. STONE; MARYANN STONE; HAROLD M. WARD and MARGARET C. WARD, husband and wife; HAYWOOD HANNA, JR. and JULIA B. HANNA, husband and wife; HAROLD M. WARD, AS TRUSTEE FOR ELAINE C. WARD, HAROLD C. WARD AND THOMAS G. WARD; HARRY C. TEAGUE and NELL R. TEAGUE; PLAZA PARK, INC., an involuntarily dissolved Florida corporation; LISA SUZANNE HALE, formerly known as LISA SUZANNE TEAGUE; KATRINA ANN TEAGUE; GENEVIEVE E. CROOKS; GEORGE COURY, AS TRUSTEE FOR MAUREEN CURRAN BELL, PATRICK WILLIAM BELL, JR., COURY JAMAIL BELL AND JOSEPH COURY LAWRENCE, AND ANY OTHER GRANDCHILDREN BORN TO OR ADOPTED BY THE CHILDREN OF AMELIA COURY, MARY ANN BELL AND PATRICIA LAWRENCE; MARY ANN BELL; PATRICIA LAWRENCE; ALVRONE SATER; GLENN H. BRACKEN; JEFF M. BRACKEN; SAM T. BRACKEN; A.Y. LEWIS; IDA BRACKEN LEWIS; ADDIE BRACKEN PRICE; ADDIE BRACKEN PRICE, TRUSTEE FOR JOHN PAUL PRICE TRUST NO. 4; ADDIE BRACKEN PRICE, TRUSTEE FOR SALLY SUE PRICE TRUST NO. 4; E.R. SMITH A/K/A ERNEST R. SMITH; GEORGE COURY, TRUSTEE; MAURINE GENECOV MUNTZ; DAN MCKENZIE; M.B. RUDMAN; ROY T. ANDERSON; JAMES LILLY, TRUSTEE; BEN E. SUTTON and ELIZABETH T. SUTTON; LAWRENCE CONSOLIDATED ENTERPRISES, LTD., a Texas limited partnership; MARTHA KATHRYN LEWIS MARSHALL; PLC O&G PROPERTIES, L.P., a Texas limited partnership; BLAIR BAX ENERGY, LLC, a Texas limited liability company; BAXSTO, LLC, a Texas limited liability company; BUFFY ENERGY, LLC, a Texas limited liability company, if alive and if dead, their respective unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against the above Defendants,
Defendants.
TO: Defendants, O.L. RAY; E. FRED HERSCHBACH; JOHN K. KEYES; REUBEN BROOKS; DR. A.H. MCCOY; EMMETTE F. GATHRIGHT; ROBERT A. HERSCHBACH; RUDMAN RESOURCES, INC., a Texas corporation; J. COLLINS WOHNER; ARDEN A. ANDERSON; PAT R. JEFFREYS, TRUSTEE; HAYWOOD HANNA, JR.; ROBERT S. DIX; E.G. STONE; MARYANN STONE; HAROLD M. WARD and MARGARET C. WARD, husband and wife; HAYWOOD HANNA, JR. and JULIA B. HANNA, husband and wife; HAROLD M. WARD, AS TRUSTEE FOR ELAINE C. WARD, HAROLD C. WARD AND THOMAS G. WARD; HARRY C. TEAGUE and NELL R. TEAGUE; PLAZA PARK, INC., an involuntarily dissolved Florida corporation; GENEVIEVE E. CROOKS; GEORGE COURY, AS TRUSTEE FOR MAUREEN CURRAN BELL, PATRICK WILLIAM BELL, JR., COURY JAMAIL BELL AND JOSEPH COURY LAWRENCE, AND ANY OTHER GRANDCHILDREN BORN TO OR ADOPTED BY THE CHILDREN OF AMELIA COURY, MARY ANN BELL AND PATRICIA LAWRENCE; MARY ANN BELL; PATRICIA LAWRENCE; ALVRONE SATER; GLENN H. BRACKEN; JEFF M. BRACKEN; SAM T. BRACKEN; A.Y. LEWIS; IDA BRACKEN LEWIS; ADDIE BRACKEN PRICE; ADDIE BRACKEN PRICE, TRUSTEE FOR JOHN PAUL PRICE TRUST NO. 4; ADDIE BRACKEN PRICE, TRUSTEE FOR SALLY SUE PRICE TRUST NO. 4; GEORGE COURY, TRUSTEE; MAURINE GENECOV MUNTZ; DAN MCKENZIE; M.B. RUDMAN; ROY T. ANDERSON; JAMES LILLY, TRUSTEE; BEN E. SUTTON and ELIZABETH T. SUTTON; LAWRENCE CONSOLIDATED ENTERPRISES, LTD., a Texas limited partnership; MARTHA KATHRYN LEWIS MARSHALL; PLC O&G PROPERTIES, L.P., a Texas limited partnership; BLAIR BAX ENERGY, LLC, a Texas limited liability company; BAXSTO, LLC, a Texas limited liability company; BUFFY ENERGY, LLC, a Texas limited liability company, and all unknown persons, if alive, and if dead, or not known to be dead or alive, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under, or against the unknown persons, and others (collectively, “Unknown Defendants”), and all unknown persons, if alive, and if dead, or not known to be dead or alive, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under, or against the unknown persons, and others, and, and all other parties having or claiming to have any right, title or interest in the real property herein described.
YOU ARE HEREBY NOTIFIED that a Verified Complaint for Partition of Mineral Interests relating to certain real property located in Pasco County, Florida, to-wit: SEE EXHIBIT A ATTACHED HERETO AND MADE A PART HEREOF, has been filed against you and you are required to serve a copy of your written defenses, if any, to Plaintiff's attorney, LEONARD H. JOHNSON, ESQUIRE, of the law firm of JOHNSON POPE BOKOR RUPPEL & BURNS LLP, whose address is 400 North Ashley Drive, Suite 3100, Tampa, Florida 33602, [email protected], telephone number (813) 225-2500, attorneys for the Plaintiff, SAV PROPERTY HOLDINGS LLC, a New Jersey limited liability company, on or before DUE ON OR BEFORE APRIL 8TH, 2024, and file the original with the Clerk of this Court either before service on the Plaintiff's attorney or immediately thereafter; otherwise a default will be entered against you for the relief demanded in the Verified Complaint for Partition of Mineral Interests.
If you are a person with a disability who needs an 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. Phone: (727) 847-8110 (voice) in New Port Richey (352)521-4274, ext 8110 (voice) in Dade City; via 1-800-955-8771 or 711 if you are hearing impaired. Contact should be initiated at least seven (7) days before the scheduled Court Appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than seven (7) days.
DATED THIS March 1, 2024
Nikki Alvarez-Sowles, Esquire,
Clerk & Comptroller
Clerk of the Circuit Court of
Pasco County
(SEAL) 2024CA000035CAAXES
03-01-2024 02:21 PM
Nikki Alvarez-Sowles
Pasco County Clerk & Comptroller
2024CA000035CAAXES
03-01-2024 02:21 PM
Deputy Clerk: Haley Joyner
EXHIBIT A
The Land referred to herein below is situated in the County of Pasco, State of Florida, and is described as follows:
PARCEL 1: A parcel of land lying in Section 20, Township 25 South, Range 20 East, Pasco County, Florida, AND being more particularly described as follows: From the Southwest corner of Section 20, Township 25 South, Range 20 East, Pasco County, Florida; thence South 89°59'42” East, AND along the South line of said Section, a distance of 442.80 feet to a point 25.00 feet East of the centerline of Pasco Road as it is now constructed; thence North 02°20'18” West, 620.18 feet to a Point of Beginning; thence continue North 02°20'18” West, 169.61 feet; thence North 10°36'58” East, 116.63 feet; thence North 89°59'40” East, 1530.10 feet; thence South 00°00'20” East, 284.00 feet; thence South 89°59'40” West, 1544.67 feet to the Point of Beginning.
PARCEL 2: A parcel of land lying in Section 20, Township 25 South, Range 20 East, Pasco County, Florida, AND being more particularly described as follows: From the Southwest corner of Section 20, Township 25 South, Range 20 East, Pasco County, Florida, thence South 89°59'42” East, AND along the South line of said Section, a distance of 442.80 feet to a point 25.00 feet East of the centerline of Pasco Road as it is now constructed; thence North 02°20'18” West, 466.90 feet to a Point of Beginning; thence continue North 02°20'18” West, 153.28 feet; thence North 89°59'40'' East, 1544.67 feet; thence South 00°00'20” East, 316.23 feet; thence North 83°48'03” West, 617.10 feet; thence North 86°13'01” West, 491.18 feet; thence North 75°48'28” West, 266.03 feet; thence South 89°33'53” West, 176.94 feet to the Point of Beginning.
INGRESS-EGRESS EASEMENT OF RECORD: Thirty (30) feet ingress-egress easement lying 15.00 feet and being continuous on each side of the following described centerline: From the Southwest corner of Section 20, Township 25 South, Range 20 East, Pasco County, Florida, thence South 89°59'42” East, and along the South line of said Section 20, a distance of 442.80 feet to a point 25.00 feet East of the centerline of Pasco Road as it is now constructed; thence North 02°20'18” West, 399.14 feet to the Point of Beginning; thence North 86°08'43” East, 176.38 feet; thence South 77°40'47” East, 376.96 feet; thence South 88°27'37” East, 991.76 feet; thence North 89°59'40” East, 660.00 feet; thence North 00°00'20” West, 767.82 feet to a point of terminus.
DESCRIPTION OF 70.0 INGRESS-EGRESS EASEMENT: A seventy (70) foot Ingress-Egress Easement lying 35.0 feet and being continuous on each side of the following described centerline: From the Southwest corner of Section 20, Township 25 South, Range 20 East, Pasco County, Florida, thence South 89°59'42” East, AND along the South line of said Section, a distance of 442.80 feet to a point 25.00 feet East of the centerline of Pasco Road as it is now constructed; thence North 02°20'18” West, 466.90 feet to a Point of Beginning; thence North 89°33'53” East, 176.94 feet; thence South 75°48'28” East, 266.03 feet; thence South 86°13'01” East, 491.18 feet; thence South 83°48'03” East, 617.10 feet to a point of terminus.
March 8, 15, 2024 24-00359P