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AMENDED NOTICE OF ACTION
IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PASCO COUNTY, FLORIDA
CIVIL DIVISION
Case No.:
512026CA000472CAAXES
RYAN COMPANIES US, INC.,
a Minnesota corporation
Plaintiff, v.
JOHN K. KEYES; REUBEN BROOKS; DR. A.H. McCOY; ROBERT A. HERSCHBACH; RAYMOND A. WILLIAMS, JR.; RUDMAN RESOURCES, INC., a Texas corporation; J. COLLINS WOHNER; ARDEN A. ANDERSON; MAURINE GENECOV MUNTZ; EMMETTE F. GATHRIGHT; HAYWOOD HANNA, JR.; E.G. STONE and MARYANN STONE; 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; LISA SUZANNE HALE, formerly known as LISA SUZANNE TEAGUE; GEORGE COURY, AS TRUSTEE FOR MAUREEN CURRAN BELL, PATRICK WILLIAM BELL, JR., COURY JAMAIL BELL AND JOSEPH COURY LAWRENCE; PATRICIA LAWRENCE; 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; J. BRADLEY JEFFREYS; JAMES LILLY, TRUSTEE; BEN E. SUTTON and ELIZABETH T. SUTTON; MOODY H. DAVIS and PATRICIA H. DAVIS; THOMAS G. THOMPSON; ROY T. ANDERSON, TRUSTEE OF THE ROY T. ANDERSON TRUST U/A DATED DECMEBER 5, 1989; COWAN MINERALS, INC., a Texas corporation; LAWRENCE CONSOLIDATED ENTERPRISES, LTD., a Texas limited partnership; MARTHA KATHRYN LEWIS MARSHALL; NANCY I. GEIGER f/k/a NANCY I. GRANTHAM; BLAIRBAX ENERGY, LLC, a Texas limited liability company; BAXSTO, LLC, a Texas limited liability company; BUFFY ENERGY, LLC, a Texas limited liability company; THE MR TRUST; RUDMAN FAMILY TRUST; JOHN K. KEYES FAMILY TRUST; ROBERT S. DIX; HAROLD M. WARD and MARGARET C. WARD, husband and wife; HAYWOOD HANNA, JR., and JULIA B. HANNA, husband and wife; GENEVIEVE E. CROOKS; FPVRTAV, LLC, a Texas limited liability company; E3 LAND & MINERALS, LLC, a Texas limited liability company; CJKJ INVESTMENTS, LLC, a Texas limited liability company; SOURCE MINERALS, LLC, a Texas limited liability company; RWTI, LLC, a Texas limited liability company; JENCO LAND, 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 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; 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; ROBERT A. HERSCHBACH, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ROBERT A. HERSCHBACH; RAYMOND A. WILLIAMS, 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 RAYMOND A. WILLIAMS, JR.; RUDMAN RESOURCES, INC., a Texas corporation; 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; 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; 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; 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, AS TRUSTEE FOR ELAINE C. WARD, HAROLD C. WARD AND THOMAS G. WARD, 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, 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; GEORGE COURY, AS TRUSTEE FOR MAUREEN CURRAN BELL, PATRICK WILLIAM BELL, JR., COURY JAMAIL BELL AND JOSEPH COURY LAWRENCE, if alive, and if dead, their unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against GEORGE COURY, AS TRUSTEE FOR MAUREEN CURRAN BELL, PATRICK WILLIAM BELL, JR., COURY JAMAIL BELL AND JOSEPH COURY LAWRENCE; GLENN H. BRACKEN, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against GLENN H. BRACKEN; JEFF M. BRACKEN, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against JEFF M. BRACKEN; SAM T. BRACKEN, if alive, and if dead, his unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against SAM T. BRACKEN; A.Y. LEWIS, 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 A.Y. LEWIS; IDA BRACKEN LEWIS, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against IDA BRACKEN LEWIS; ADDIE BRACKEN PRICE, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ADDIE BRACKEN PRICE; ADDIE BRACKEN PRICE, TRUSTEE FOR JOHN PAUL PRICE TRUST NO. 4, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ADDIE BRACKEN PRICE, TRUSTEE FOR JOHN PAUL PRICE TRUST NO. 4; ADDIE BRACKEN PRICE, TRUSTEE FOR SALLY SUE PRICE TRUST NO. 4, if alive, and if dead, her unknown spouses, heirs, devisees, grantees, assignees, lienors, creditors, trustees or other persons claiming by, through, under or against ADDIE BRACKEN PRICE, TRUSTEE FOR SALLY SUE PRICE TRUST NO. 4; ROY T. ANDERSON, TRUSTEE OF THE ROY T. ANDERSON TRUST U/A DATED DECMEBER 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 THE ROY T. ANDERSON TRUST U/A DATED DECMEBER 5, 1989; BAXSTO, LLC, a Texas limited liability company; JOHN K. KEYES FAMILY TRUST; 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 ROBERT S. DIX; 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; 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; SOURCE MINERALS, 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 above-named Defendants (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, and SHEADA MADANI, 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] or [email protected], telephone number (813) 225-2500, attorneys for the Plaintiff, RYAN COMPANIES US, INC., a Minnesota corporation, on or before JULY 13, 2026, 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.
EXHIBIT A
THE LAND REFERRED TO HEREIN BELOW IS SITUATED IN THE COUNTY OF PASCO, STATE OF FLORIDA, AND IS DESCRIBED AS FOLLOWS:
COMMENCE AT THE SOUTHEAST CORNER OF THE SOUTHWEST 1/4 OF SECTION 29, TOWNSHIP 25 SOUTH, RANGE 20 EAST, PASCO COUNTY, FLORIDA, FOR A POINT OF BEGINNING, THENCE WEST ALONG THE SOUTH LINE OF SAID SECTION 29, 1744.01 FEET; THENCE N09°50’00”E, 1175.0 FEET; THENCE S81°30’00”E, 764.72 FEET; THENCE N74°24’00”E, 372.50 FEET; THENCE S49°41’E, 558.51 FEET (D) (558.55 FEET FIELD), TO THE EAST LINE OF THE SOUTHWEST 1/4 OF SAID SECTION 29; THENCE S00°10’30”E, 783.52 FEET (D) (S00°10’21”E, 783.49 FEET FIELD), ALONG SAID EAST LINE OF THE SOUTHWEST 1/4, TO THE POINT OF BEGINNING, LESS RIGHT OF WAY FOR OVERPASS ROAD AND ALSO LESS THAT PORTION TAKEN BY THE STATE ROAD DEPARTMENT OF THE STATE OF FLORIDA, AN AGENCY OF THE STATE OF FLORIDA, AS SET FORTH ON THAT CERTAIN FINAL JUDGEMENT DATED APRIL 4, 1963 AND RECORDED IN CIRCUIT COURT MINUTE BOOK D, PAGE 271, PUBLIC RECORDS, PASCO COUNTY, FLORIDA, BEING DESCRIBED AS THE NORTH 80.0 FEET OF THE SOUTH 100.0 FEET OF THE EAST 548.64 FEET OF SAID SOUTHWEST 1/4 AND ALSO LESS RIGHT OF WAY FOR OLD PASCO ROAD, BEING FURTHER DESCRIBED AS FOLLOWS:
COMMENCE AT THE SOUTHEAST CORNER OF THE SOUTHWEST 1/4 OF SECTION 29, TOWNSHIP 25 SOUTH, RANGE 20 EAST, PASCO COUNTY, FLORIDA, THENCE N00°10’21”W ALONG THE EAST LINE OF THE SOUTHWEST 1/4 OF SAID SECTION 29, 100.00 FEET TO A POINT ON THE NORTHERLY RIGHT OF WAY LINE OF OVERPASS ROAD AND THE POINT OF BEGINNING; THENCE ALONG THE NORTHERLY RIGHT OF WAY LINE OF OVERPASS ROAD AND THE EASTERLY RIGHT OF WAY LINE OF OLD PASCO ROAD THE NEXT (7) SEVEN COURSES; (1) WEST 548.64 FEET; (2) S00°10’21”E, 80.00 FEET; (3) WEST, 1160.85 FEET; (4) N24°27’22”W, 20.06 FEET; (5) N10°04’17”E, 167.23 FEET; (6) N09°56’46”E, 777.66 FEET; (7) N09°35’29”E, 188.43 FEET; THENCE LEAVING SAID RIGHT OF WAY LINE S81°30’00”E, 744.04 FEET; THENCE N74°24’00”E, 372.50 FEET; THENCE S49°41’00”E, 558.55 FEET TO A POINT ON THE EAST BOUNDARY OF THE SOUTHWEST 1/4 OF SECTION 29; THENCE S00°10’21”E, ALONG SAID EAST BOUNDARY, 683.49 FEET TO THE POINT OF BEGINNING.
AND LESS AND EXCEPT THAT PORTION DESCRIBED IN STIPULATED ORDER OF TAKING AND FINAL JUDGMENT RECORDED SEPTEMBER 15, 2020, IN BOOK 10176, PAGE 3291, PUBLIC RECORDS OF PASCO COUNTY, FLORIDA.
AND ALSO LESS AND EXCEPT THAT PORTION CONVEYED TO PASCO COUNTY, A POLITICAL SUBDIVISION OF THE STATE OF FLORIDA IN SPECIAL WARRANTY DEED RECORDED JANUARY 05, 2022 IN BOOK 10516, PAGE 2622, PUBLIC RECORDS OF PASCO COUNTY, FLORIDA.
PARCEL 2:
A PARCEL OF LAND BEING A PORTION OF THAT CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226, OF THE PUBLIC RECORDS OF PASCO COUNTY, FLORIDA, LYING IN SECTION 29, TOWNSHIP 25 SOUTH, RANGE 20 EAST, PASCO COUNTY, FLORIDA, BEING MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGIN AT THE SOUTHEAST CORNER ACCORDING TO THE PLAT OF PARK MEADOWS PHASE 2, AS RECORDED IN PLAT BOOK 88, PAGE 34, OF THE PUBLIC RECORDS OF PASCO COUNTY, FLORIDA, SAME BEING THE SOUTHEAST CORNER OF THE NORTH 1/2 OF THE SOUTHWEST 1/4 OF SECTION 29, TOWNSHIP 25 SOUTH, RANGE 20 EAST, PASCO COUNTY, FLORIDA, SAME ALSO BEING A POINT ON THE EAST LINE OF THAT CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226, OF THE PUBLIC RECORDS OF PASCO COUNTY, FLORIDA; THENCE S00°14’28”E, ALONG THE EAST LINE OF SAID SOUTHWEST 1/4 OF SECTION 29, SAME BEING SAID EAST LINE OF THAT CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226, FOR 539.79 FEET TO THE SOUTHEAST CORNER OF SAID CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226; THENCE THE FOLLOWING THREE (3) COURSES ALONG THE SOUTHERLY LINE OF SAID CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226; (1) THENCE LEAVING SAID EAST LINE OF THE SOUTHWEST 1/4 OF SECTION 29, N49°45’28”W, FOR 558.73 FEET; (2) THENCE S74°19’32”W, FOR 372.50 FEET; (3) THENCE N81°34’28”W, FOR 629.10 FEET TO THE POINT OF INTERSECTION WITH A NON-TANGENT CURVE, CONCAVE WESTERLY, SAME BEING THE SOUTHEAST CORNER OF ADDITIONAL RIGHT-OF-WAY OF OLD PASCO ROAD, PARCEL 159.2, AS DESCRIBED IN OFFICIAL RECORDS BOOK 6267, PAGE 602, OF THE PUBLIC RECORDS OF PASCO COUNTY, FLORIDA, SAME ALSO BEING THE SOUTHWEST CORNER OF SAID CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226; THENCE NORTHERLY ALONG THE ARC OF SAID CURVE, SAME BEING THE EASTERLY RIGHT-OF-WAY LINE OF ADDITIONAL RIGHT-OF-WAY OF OLD PASCO ROAD, PARCEL 159.2, SAME ALSO BEING THE WEST LINE OF SAID CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226, WITH A RADIAL BEARING OF N81”42’08”W, HAVING A RADIUS OF 2,368.50 FEET, A CENTRAL ANGLE OF 04°30’50”, AN ARC LENGTH OF 186.59 FEET, AND A CHORD BEARING N06°02’27”E, FOR 186.54 FEET, TO THE POINT OF INTERSECTION WITH A NON-TANGENT LINE, SAME BEING THE SOUTH LINE OF SAID NORTH 1/2 OF THE SOUTHWEST 1/4 OF SECTION 29, SAME ALSO BEING THE SOUTHWEST CORNER ACCORDING TO SAID PLAT OF PARK MEADOWS PHASE 2; THENCE LEAVING SAID EASTERLY RIGHT-OF-WAY LINE OF ADDITIONAL RIGHT- OF-WAY OF OLD PASCO ROAD, PARCEL 159.2, SAME BEING SAID WEST LINE OF THAT CERTAIN PROPERTY AS DESCRIBED IN OFFICIAL RECORDS BOOK 9756, PAGE 226, N89°55’34”E, ALONG SAID SOUTH LINE OF THE NORTH 1/2 OF SOUTHWEST 1/4 OF SECTION 29, SAME BEING THE SOUTH LINE OF SAID PLAT OF PARK MEADOWS PHASE 2 (BEING THE BASIS OF BEARINGS FOR THIS LEGAL DESCRIPTION), FOR 1,385.55 FEET TO THE POINT OF BEGINNING (collectively, the “Property”).
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 Office of the Court Administrator, 7530 Little Road, Port Richey, FL 34654, (727) 847-8135, at least seven days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than seven days; if you are hearing or voice impaired, call 711.
DATED THIS June 8, 2026.
Nikki Alvarez-Sowles, Esquire,
Clerk & Comptroller
Clerk of the Circuit Court
of Pasco County
By: Haley Joyner (Seal)
As: Deputy Clerk
June 12, 19, 26; July 3, 2026 26-01344P
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