On January 23, 2015 a
Answer
was filed
in the District Court of Oklahoma County.
Preview
MVM
1030681248
MID-CONTINENT CASUALTY CO.,
Plaintiff,
vs.
SDF CONSTRUCTION, LLC.; STEVEN
D. FRAKES; SDF INVESTMENTS,
LLC; MICHELLE BIRNEY, Administrator
of the Estate of MICHAEL JAMES
BIRNEY, Deceased; TERESA BIRNEY,
Special Administrator of the Estate of
DANIEL LEO BIRNEY, Deceased; and
PRESTON GAEDE,
Defendants.
IN THE DISTRICT COURT FOR OKLAHOMA COUNTY
STATE OF OKLAHOMA
C3-20IFR- Yyr
CBee 88-
(Judge Prince)
Case No.
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SPECIAL ENTRY OF APPEARANCE
COME NOW, the Defendants, SDF Construction, LLC, Steven D.Frakes, SDF Investments,
LLC, and pursuant to the provisions of 12 O. S. §2012(A) and Young v. Walton, 807 P.2d 248
(Okla. 1991), herein specially enter their appearance and requests 20 additional days, up to and
including September 7, 2015, in which to Answer or otherwise plead.
Respectfully Submitted,
LEE, GOODWIN, L
LEWIS & Di /
KYLE W. ODWIN, OBA # 17036
1300 E. nit 1
Edmond, OK 73034
(405) 330-0118
(405) 330-0767 (fax)
kgoodwin@edmondlawoffice.comCERTIFICATE OF MAILING
The undersigned does hereby certify that a true and correct copy of the above and joing
pleading was deposited into the United States Mails, first class postage prepaid on this of
August, 2015 addressed to the following persons:
F. Thomas Cordell, Esq.
FRAILEY, CHAFFIN, CORDELL, PERRYMAN
STERKEL, McCALLA & BROWN, LLP
201 N. 4" Street
P.O. Box 533
Chickasha, OK 73023
Jim Loftis, Esq.
LOFTIS & BARNARD
225 N. Peters, Suite 1
Norman, OK 73069
John P. Zelbst, Esq.
ZELBST, HOLMES & BUTLER
P.O. Box 365
Lawton, OK 73502
KYLE en \
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Document Filed Date
August 21, 2015
Case Filing Date
January 23, 2015
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