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Filing # 166902205 E-Filed 02/15/2023 06:24:20 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT
IN AND FOR CITRUS COUNTY, FLORIDA
CIVIL DIVISION
CITRUS COUNTY, FLORIDA, a political
subdivision of the State of Florida,
Petitioner, Case No.: 2023 CA 000111 A
VS. Section:
LPC OWNERS ASSOCIATION, INC., a Florida Parcel No.: 2018
not-for-profit corporation; AMZA II, LLC, a
Florida limited liability company; DR.
MICHAEL HASHEMIAN, an individual;
MICHAEL M. HASHEMIAN, DMD, MD, PA
d/b/a DENTOFACIAL & COSMETIC
SURGERY INSTITUTE, a Florida corporation;
CITRUS COUNTY PROPERTY APPRAISER
and CITRUS COUNTY TAX COLLECTOR,
Respondents.
SUMMONS TO SHOW CAUSE
IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA:
TO ALL AND SINGULAR SHERIFFS OF THE STATE:
YOU ARE HEREBY COMMANDED to serve this Summons to Show Cause, along with
a copy of the Petition in Eminent Domain or in the Alternative Complaint for Specific
Performance, Declaration of Taking, Notice of Email Designation, and Notice of Lis Pendens
upon the following Respondent:
Janice A. Warren, Citrus County Tax Collector
210 N Apopka Ave, Suite 100
Inverness, FL 34450
NOTICE IS HEREBY GIVEN TO THE NAMED RESPONDENT AND TO ALL
WHOM IT MAY CONCERN, including all parties claiming any interest by, through, under or
against the named Respondent; and to all having or claiming to have any right, title, or interest in
the property sought to be taken that a Petition in Eminent Domain and a Declaration of Taking
have been filed in the above-styled cause by the Petitioner, CITRUS COUNTY, FLORIDA.
YOU AND EACH OF YOU are required to serve written defenses to the Petition upon
the Petitioner’s attorney, W. Campbell McLean, of GrayRobinson, P.A., 401 E. Jackson Street,
Suite 2700, Tampa, FL 33602, on or before March 16, 2023 and to file the original of the
written defenses with the Clerk of this Court either before service on Petitioner’s attorney or
immediately thereafter, showing what right, title or interest you or any of you have in and to the
property described in the Petition and to show cause why that property should not be taken for
the uses and purposes set forth in said Petition. If any Respondent fails to do so, a default will be
entered against that Respondent for the relief demanded in the Petition.
YOU ARE FURTHER NOTIFIED, that the Petitioner, pursuant to the provisions of
§ 74.051, Florida Statutes, will apply for an Order of Taking to the Honorable Carol Falvey, one
of the Judges of the Circuit Court of the Fifth Judicial Circuit, in and for Citrus County, Florida,
on Wednesday, March 22, 2023 at 10:00 a.m., Room 1-303, of the Citrus County Courthouse
located at 110 N. Apopka Avenue, Inverness, Florida, 34450, for a hearing to determine (1) the
jurisdiction of the Court, (2) the sufficiency of the pleadings, (3) whether the Petitioner is
properly exercising its delegated authority, (4) the amount to be deposited for the property
sought to be appropriated, (5) the terms and conditions upon which title to and possession of said
property may become vested in Petitioner, and such other matters as the Court may deem
appropriate. The Respondent in this action may request a hearing at the time and place
designated and be heard. Any Respondent failing to timely file a request for hearing, in
compliance with Florida law, shall waive any right to object to the Order of Taking.
WITNESS my hand and the seal of this Court on this_20 day of _ Feb. 2023
SY
st Coury My
Angela Vick ZS.
Zs
Clerk of the Circuit Court
4,
oS
By:_(Avl A Broilo, Wy <<
As Deputy Clerk 7
CITRUS COUNTY, FLORIDA
a political subdivision of the
State of Florida, Petitioner
W. CAMPBELL MCLEAN, ESQUIRE
Florida Bar Number: 0141402
campbell.mclean@gray-robinson.com
deborah.cook@gray-robinson.com
KENT L. HIPP, ESQUIRE
Florida Bar Number: 879630
kent.hipp@gray-robinson.com
carol.ramirez@gray-robinson.com
SUMMER E. DEGEL, ESQUIRE
Florida Bar. No.: 106536
Summer.degel@gray-robinson.com
GrayRobinson, P.A.
401 E. Jackson Street, Suite 2700
Tampa, FL 33602
Telephone: (813) 273-5000
Fax: (813) 273-5145
Attorneys for Petitioner
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 ADA Coordinator at the
Office of the Trial Court Administrator, Citrus County Courthouse, 110
North Apopka Avenue, Inverness, Florida 34450, Telephone (352) 341-6700,
at least 7 days before your scheduled court appearance, or immediately upon
receiving notification if the time before the scheduled appearance is less than
7 days; if you are hearing or voice impaired, call 711.
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Filing # 166902205 E-Filed 02/15/2023 06:24:20 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT IN AND FOR CITRUS COUNTY, FLORIDA CIVIL DIVISION CITRUS COUNTY, FLORIDA, a political subdivision of the State of Florida, Petitioner, Case No.: 2023 CA 000111 A VS. Section: LPC OWNERS ASSOCIATION, INC., a Florida Parcel No.: 2018 not-for-profit corporation; AMZA II, LLC, a Florida limited liability company; DR. MICHAEL HASHEMIAN, an individual; MICHAEL M. HASHEMIAN, DMD, MD, PA d/b/a DENTOFACIAL & COSMETIC SURGERY INSTITUTE, a Florida corporation; CITRUS COUNTY PROPERTY APPRAISER and CITRUS COUNTY TAX COLLECTOR, Respondents. SUMMONS TO SHOW CAUSE IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA: TO ALL AND SINGULAR SHERIFFS OF THE STATE: YOU ARE HEREBY COMMANDED to serve this Summons to Show Cause, along with a copy of the Petition in Eminent Domain or in the Alternative Complaint for Specific Performance, Declaration of Taking, Notice of Email Designation, and Notice of Lis Pendens upon the following Respondent: Janice A. Warren, Citrus County Tax Collector 210 N Apopka Ave, Suite 100 Inverness, FL 34450 NOTICE IS HEREBY GIVEN TO THE NAMED RESPONDENT AND TO ALL WHOM IT MAY CONCERN, including all parties claiming any interest by, through, under or against the named Respondent; and to all having or claiming to have any right, title, or interest in the property sought to be taken that a Petition in Eminent Domain and a Declaration of Taking have been filed in the above-styled cause by the Petitioner, CITRUS COUNTY, FLORIDA. YOU AND EACH OF YOU are required to serve written defenses to the Petition upon the Petitioner’s attorney, W. Campbell McLean, of GrayRobinson, P.A., 401 E. Jackson Street, Suite 2700, Tampa, FL 33602, on or before March 16, 2023 and to file the original of the written defenses with the Clerk of this Court either before service on Petitioner’s attorney or immediately thereafter, showing what right, title or interest you or any of you have in and to the property described in the Petition and to show cause why that property should not be taken for the uses and purposes set forth in said Petition. If any Respondent fails to do so, a default will be entered against that Respondent for the relief demanded in the Petition. YOU ARE FURTHER NOTIFIED, that the Petitioner, pursuant to the provisions of § 74.051, Florida Statutes, will apply for an Order of Taking to the Honorable Carol Falvey, one of the Judges of the Circuit Court of the Fifth Judicial Circuit, in and for Citrus County, Florida, on Wednesday, March 22, 2023 at 10:00 a.m., Room 1-303, of the Citrus County Courthouse located at 110 N. Apopka Avenue, Inverness, Florida, 34450, for a hearing to determine (1) the jurisdiction of the Court, (2) the sufficiency of the pleadings, (3) whether the Petitioner is properly exercising its delegated authority, (4) the amount to be deposited for the property sought to be appropriated, (5) the terms and conditions upon which title to and possession of said property may become vested in Petitioner, and such other matters as the Court may deem appropriate. The Respondent in this action may request a hearing at the time and place designated and be heard. Any Respondent failing to timely file a request for hearing, in compliance with Florida law, shall waive any right to object to the Order of Taking. WITNESS my hand and the seal of this Court on this_20 day of _ Feb. 2023 SY st Coury My Angela Vick ZS. Zs Clerk of the Circuit Court 4, oS By:_(Avl A Broilo, Wy << As Deputy Clerk 7 CITRUS COUNTY, FLORIDA a political subdivision of the State of Florida, Petitioner W. CAMPBELL MCLEAN, ESQUIRE Florida Bar Number: 0141402 campbell.mclean@gray-robinson.com deborah.cook@gray-robinson.com KENT L. HIPP, ESQUIRE Florida Bar Number: 879630 kent.hipp@gray-robinson.com carol.ramirez@gray-robinson.com SUMMER E. DEGEL, ESQUIRE Florida Bar. No.: 106536 Summer.degel@gray-robinson.com GrayRobinson, P.A. 401 E. Jackson Street, Suite 2700 Tampa, FL 33602 Telephone: (813) 273-5000 Fax: (813) 273-5145 Attorneys for Petitioner 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 ADA Coordinator at the Office of the Trial Court Administrator, Citrus County Courthouse, 110 North Apopka Avenue, Inverness, Florida 34450, Telephone (352) 341-6700, at least 7 days before your scheduled court appearance, or immediately upon receiving notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711.