On August 20, 2012 a
Party Notice
was filed
involving a dispute between
Moore, Donnie M,
and
Laurel Oak Country Club Inc,
in the District Court of Sarasota County.
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eFile Accepted: 01/07/2015 04:33 PM
Filing # 22280876 E-Filed 01/07/2015 03:34:27 PM
IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
IN AND FOR SARASOTA COUNTY FLORIDA
DONNIE M. MOORE
Plaintiff,
Vv. Case No.: 2012 CA 6708 NC
LAUREL OAK COUNTRY CLUB, INC.
Defendant.
/
NOTICE OF COMPLIANCE WITH
FLORIDA RULE OF CIVIL PROCEDURE 1.071
The undersigned hereby gives notice of compliance with Fla. R. Civ. P. 1.071, with
respect to its Fifteenth Affirmative Defense filed in this case challenging the application of
section 617.0605(3), Florida Statutes, to the By-Laws of Laurel Oak Country Club, Inc. in
effect prior to the enactment of that section of the Florida Statutes and to treating Laurel
Oak Country Club, Inc. as a mutual benefit corporation, as defined in section 617.01401,
Florida Statutes, for contracts which it had entered into prior to section 617.01401’s
effective date on the basis that such would unlawfully impair its contracts, including its
By-Laws, in violation of Art. |, §10 of the Florida Constitution and Art. |, §10, of the United
_ States Constitution. The undersigned is complying with Fla. R. Civ. P. 1.071 by serving,
as indicated below, the State Attorney for the Twelfth Judicial Circuit by certified or
registered mail with a copy of the Amended Answer And Affirmative Defenses To
Amended Complaint which it filed in this case on or about October 28, 2014 challenging
the application of those statutes.CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true copy of the foregoing has been furnished this 7th
day of January, 2015 by email via the Florida Courts E-filing Portal to Mark A. Hanson,
Esq., Law Offices of Lobeck and Hanson, P.A., 2033 Main Street, Ste. 403, Sarasota, FL
3423/7 at mhanson@lobeckhanson.com, and by Certified Mail to Ed Brodsky, Florida
State Attorney, 12th Judicial Circuit, 2071 Ringling Boulevard, Suite 400, Sarasota, FL
34237, along with a copy of the Amended Answer And Affirmative Defenses To Amended
Complaint filed in this case on or about October 28, 2014.
WALTERS LEVINE
KLINGENSMITH & THOMISON, P.A.
1819 Main Street, Suite 1110
Sarasota, Florida 34236
Telephone No.: (941) 364-8787
Telecopier No.: (941) 361-3023
Attorneys for Defendant
-
i # ‘, :
: ft me f oe
Joel W. Walters, ‘Esq.
Florida Bar No.: 604356
iwalters@walterslevine.com
Michael J. Pugh, Esq.
Florida Bar No.: 175547
mpugh@wailtersievine.com
1478-01 7/Laurei Oak/Pleadings/Notice of Compliance 1.071
Document Filed Date
January 07, 2015
Case Filing Date
August 20, 2012
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eFile Accepted: 01/07/2015 04:33 PM Filing # 22280876 E-Filed 01/07/2015 03:34:27 PM IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY FLORIDA DONNIE M. MOORE Plaintiff, Vv. Case No.: 2012 CA 6708 NC LAUREL OAK COUNTRY CLUB, INC. Defendant. / NOTICE OF COMPLIANCE WITH FLORIDA RULE OF CIVIL PROCEDURE 1.071 The undersigned hereby gives notice of compliance with Fla. R. Civ. P. 1.071, with respect to its Fifteenth Affirmative Defense filed in this case challenging the application of section 617.0605(3), Florida Statutes, to the By-Laws of Laurel Oak Country Club, Inc. in effect prior to the enactment of that section of the Florida Statutes and to treating Laurel Oak Country Club, Inc. as a mutual benefit corporation, as defined in section 617.01401, Florida Statutes, for contracts which it had entered into prior to section 617.01401’s effective date on the basis that such would unlawfully impair its contracts, including its By-Laws, in violation of Art. |, §10 of the Florida Constitution and Art. |, §10, of the United _ States Constitution. The undersigned is complying with Fla. R. Civ. P. 1.071 by serving, as indicated below, the State Attorney for the Twelfth Judicial Circuit by certified or registered mail with a copy of the Amended Answer And Affirmative Defenses To Amended Complaint which it filed in this case on or about October 28, 2014 challenging the application of those statutes.CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true copy of the foregoing has been furnished this 7th day of January, 2015 by email via the Florida Courts E-filing Portal to Mark A. Hanson, Esq., Law Offices of Lobeck and Hanson, P.A., 2033 Main Street, Ste. 403, Sarasota, FL 3423/7 at mhanson@lobeckhanson.com, and by Certified Mail to Ed Brodsky, Florida State Attorney, 12th Judicial Circuit, 2071 Ringling Boulevard, Suite 400, Sarasota, FL 34237, along with a copy of the Amended Answer And Affirmative Defenses To Amended Complaint filed in this case on or about October 28, 2014. WALTERS LEVINE KLINGENSMITH & THOMISON, P.A. 1819 Main Street, Suite 1110 Sarasota, Florida 34236 Telephone No.: (941) 364-8787 Telecopier No.: (941) 361-3023 Attorneys for Defendant - i # ‘, : : ft me f oe Joel W. Walters, ‘Esq. Florida Bar No.: 604356 iwalters@walterslevine.com Michael J. Pugh, Esq. Florida Bar No.: 175547 mpugh@wailtersievine.com 1478-01 7/Laurei Oak/Pleadings/Notice of Compliance 1.071