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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.:
2024CA001644AAXES
MASSEY PARTNERS, LTD.,
a Florida limited partnership
Plaintiff, v.
JOHN K. KEYES; REUBEN BROOKS; MYER A. RABINOWITZ; B.L. WOOLLEY; G.L. GILBERT; D.C. LATIMER; TIP RAY; THE OHIO OIL COMPANY; R.J.
FULLER; JOHN P. WEMPLE; DABNEY COMPANY, a
partnership; DR. A.H. McCOY; EMMETTE F. GATHRIGHT;
J. COLLINS WOHNER; ARDEN A. ANDERSON; PAT R. JEFFREYS, TRUSTEE; MAURINE GENECOV MUNTZ; HAYWOOD HANNA, JR.; ROBERT S. DIX; MELBA R. DIX;
E.G. STONE and 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, husband and wife; PLAZA PARK, INC., an involuntarily dissolved Florida corporation; RUTH R. STONE; GENEVIEVE E. CROOKS; PATRICIA LAWRENCE; PHILIP B. BERRY; RUTH FALK BERRY;
ALYNE T. PATRICK; SOL BRONSTEIN; DAN McKENZIE;
WILLIAM L. BALDWIN; MARY L. ALBRIGHT; JONATHAN B. WEAVER; FRANCIS G. BALDWIN III; ROY T. ANDERSON, TRUSTEE OF THE ROY T. ANDERSON
TRUST U/A DATED DECEMBER 5, 1989; JAMES LILLY, TRUSTEE; BEN E. SUTTON and ELIZABETH T. SUTTON; MOODY H. DAVIS and PATRICIA H. DAVIS, husband and
wife; THOMAS G. THOMPSON; WALLACE CHRISTENSEN; THE SATER FAMILY PARTNERSHIP, L.P., a Missouri limited partnership; NEW GENERATION PETROLEUM GP, LLC, a Texas limited liability company; RUTH FALK BERRY REVOCABLE TRUST; PHILIP B.
BERRY MANAGEMENT TRUST A; PATRICIA ANN HARRISON; BETTY LEE SHORE; JANE FOSTER HENLEY; BLAIRBAX 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, JOHN K. KEYES, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JOHN K. KEYES; REUBEN BROOKS, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against REUBEN BROOKS; MYER A. RABINOWITZ, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against MYER A. RABINOWITZ; B.L. WOOLLEY, if alive, and if dead, his/her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against B.L. WOOLLEY; G.L. GILBERT, if alive, and if dead, his/her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against G.L. GILBERT; D.C. LATIMER, if alive, and if dead, his/her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against D.C. LATIMER; TIP RAY, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against TIP RAY; THE OHIO OIL COMPANY; R.J. FULLER, if alive, and if dead, his/her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against R.J. FULLER; JOHN P. WEMPLE, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JOHN P. WEMPLE; DABNEY COMPANY, a partnership; DR. A.H. McCOY, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against DR. A.H. McCOY; EMMETTE F. GATHRIGHT, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against EMMETTE F. GATHRIGHT; J. COLLINS WOHNER, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against J. COLLINS WOHNER; ARDEN A. ANDERSON, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ARDEN A. ANDERSON; PAT R. JEFFREYS, TRUSTEE, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against PAT R. JEFFREYS, TRUSTEE; MAURINE GENECOV MUNTZ, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against MAURINE GENECOV MUNTZ; HAYWOOD HANNA, JR., if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against HAYWOOD HANNA, JR.; ROBERT S. DIX, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ROBERTS. DIX; MELBA R. DIX, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against MELBA R. DIX; E.G. STONE and MARYANN STONE, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against E.G. STONE and MARYANN STONE; HAROLD M. WARD and MARGARET C. WARD, husband and wife, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against HAROLD M. WARD and MARGARET C. WARD, husband and wife; HAYWOOD HANNA, JR., and JULIA B. HANNA, husband and wife, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against 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, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against HAROLD M. WARD, AS TRUSTEE FOR ELAINE C. WARD, HAROLD C. WARD AND THOMAS G. WARD; HARRY C. TEAGUE and NELL R. TEAGUE, husband and wife, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against HARRY C. TEAGUE and NELL R. TEAGUE, husband and wife; PLAZA PARK, INC., an involuntarily dissolved Florida corporation; RUTH R. STONE, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against RUTH R. STONE; GENEVIEVE E. CROOKS, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against GENEVIEVE E. CROOKS; PATRICIA LAWRENCE, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against PATRICIA LAWRENCE; PHILIP B. BERRY, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against PHILIP B. BERRY; RUTH FALK BERRY, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against RUTH FALK BERRY; ALYNE T. PATRICK, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ALYNE T. PATRICK; SOL BRONSTEIN, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against SOL BRONSTEIN; DAN McKENZIE, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against DAN McKENZIE; WILLIAM L. BALDWIN, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against WILLIAM L. BALDWIN; MARYL. ALBRIGHT, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against MARYL. ALBRIGHT; JONATHAN B. WEAVER, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JONATHAN B. WEAVER; FRANCIS G. BALDWIN III, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against FRANCIS G. BALDWIN III; ROY T. ANDERSON, TRUSTEE OF THE ROY T. ANDERSON TRUST U/A DATED DECEMBER 5, 1989, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ROY T. ANDERSON, TRUSTEE OF HE ROY T. ANDERSON TRUST U/A DATED DECEMBER 5, 1989; JAMES LILLY, TRUSTEE, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JAMES LILLY, TRUSTEE; BENE. SUTTON and ELIZABETH T. SUTTON, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against BEN E. SUTTON and ELIZABETH T. SUTTON; MOODY H. DAVIS and PATRICIA H. DAVIS, husband and wife, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against MOODY H. DAVIS and PATRICIA H. DAVIS, husband and wife; NEW GENERATION PETROLEUM GP, LLC, a Texas limited liability company; RUTH FALK BERRY REVOCABLE TRUST; PHILIP B. BERRY MANAGEMENT TRUST A; PATRICIA ANN HARRISON, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against PATRICIA ANN HARRISON; BETTY LEE SHORE, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against BETTY LEE SHORE; JANE FOSTER HENLEY, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JANE FOSTER HENLEY; BLAIRBAX ENERGY, LLC, a Texas limited liability company; BAXSTO, LLC, a Texas limited liability company; and all unknown persons, if alive, and if dead, or not known to be dead or alive, their respective 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 Plaintiffs 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, MASSEY PARTNERS, LTD., a Florida limited partnership, on or before November 18th, 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 September 24, 2024
Nikki Alvarez-Sowles, Esquire,
Clerk & Comptroller
Clerk of the Circuit Court of
Pasco County
(SEAL)
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 I:
The North 1/2 of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 of Section 11, Township 25 South, Range 20 East, Pasco County, Florida. The North 229 feet of the South 1/2 of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 of Section 11, Township 25 South, Range 20 East, Pasco County, Florida.
Less and Except that portion conveyed in Warranty Deed recorded in Book 9366, Page 2934, as corrected by Corrective Warranty Deed recorded in Book 9368, Page 2989.
Parcel II:
A portion of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 of Section 11, Township 25 South, Range 20 East, Pasco County, Florida, being more particularly described as follows:
For a POINT OF REFERENCE, commence at the Southeast corner of the Northwest 1/4 of said Section 11; thence N.00°38'03”E. along the East boundary of the Northwest 1/4 of said Section 11, a distance of 768.41 feet to the Southeast corner of the North 229.00 feet of the South 1/2 of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 of said Section 11; thence N.89°50'06”W. along the South boundary of the North 229.00 feet of the South 1/2 of the North 1/2 of the Southeast 1/4 of the Northeast 1/4 of said Section 11, 100.00 feet for a POINT OF BEGINNING; thence continue along said South boundary N.89°50'06”W., a distance of 329.32 feet; thence N.00°38'03”W., a distance of 264.54 feet; thence S.89°50'06”E., 329.32 feet; thence S.00°38'03”W., 264.54 feet to the POINT OF BEGINNING.
TOGETHER WITH:
A 30.00' easement for ingress/egress as follows:
For a POINT OF REFERENCE, commence at the Southeast corner of the Northwest 1/4 of said Section 11; thence N.00°38'03”E. along the East boundary of the Northwest 1/4 of said Section 11, a distance of 768.41 feet to the Southeast corner of the North 229.00 feet of the South 1/2 of the North 1/2 of the Southwest 1/4 of the Northwest 1/4 of said Section 11; thence N.89°50'06”W. along the South boundary of the North 229.00 feet of the South 1/2 of the North 1/2 of the Southeast 1/4 of the Northeast 1/4 of said Section 11, 100.00 feet; thence N.00°38'03”E., 149.37 feet for a POINT OF BEGINNING; thence continue N.00°38'03”E., 38.50 feet, thence N.51'48'55”E., 128.35 feet to the aforementioned East boundary of the Northwest 1/4 of said Section 11, also being the West right-of-way line of Oak Street (a public right-of-way); thence along said East boundary and West right-of-way of Oak Street, S.00°38'03”W., 38.50 feet to the Northeast corner of the North 229.00 feet of the South 1/2 of the North 1/2 of the Southeast corner of the Northwest 1/4 of said Section 11, thence S.51°48'55”W., 128.35 feet to the POINT OF BEGINNING.
Parcel III:
The Southeast 1/4 of the Northwest 1/4 of Section 11, Township 25 South, Range 20 East, LESS the North 1/2 of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 and LESS the North 229.0 feet of the South 1/2 of the North 1/2 of the Southeast 1/4 of the Northwest 1/4 lying and being in Pasco County, Florida.
And
An Easement for access over, upon and across the following described property: The West 60.00 feet of the South 1/2 of the Northwest 1/4 of the Southwest 1/4 of the Northeast 1/4 and the West 60.00 feet of the North 300.00 feet of the Southwest 1/4 of the Southwest 1/4 of the Northeast 1/4 of Section 11, Township 25 South, Range 20 East, Pasco County, Florida.
Less and except from all of the above any land described in the Stipulated Order of Taking recorded in Official Records Book 9826, Page 1164, Public Records of Pasco County, Florida.
Parcel Numbers:
11-25-20-0000-01600-0010,
11-25-20-0000-01600-0011 and 11-25-20-0000-01100-0010
Oct. 18, 25; Nov. 1, 8, 2024 24-01920P