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  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
  • SUNTRUST BANK vs COOLEY, JONATHAN et al document preview
						
                                

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IN THE CIRCUIT COURT OF THE SUNTRUST BANK, 12TH JUDICIAL CIRCUIT, IN AND FOR Plaintiff, SARASOTA COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 2007-CA-007980-SC vs. et al, TODD J. MCNALLY, Defendants. MOTION FOR DEFAULT Plaintiff moves for entry of a Default by the Clerk against Defendants, TODD J. MCNALLY, SUZANNE TOALE, SUNTRUST BANK and JOHN DOE N/K/A KAREEM SUWAITY for failure to serve any paper on the undersigned or file any paper as required by law. NOTE TO CLERK: In the event that any of the aforenamed defendants have timely filed any paper in the above-styled cause, or should their return of service not be filed, then please strike the name of such defendant from the above motion. I HEREBY CERTIFY that a true copy of the foregoing Motion for Default and Non-Military Affidavit, were delivered to the parties on the attached [7 say of September, 2007. Law Offices of Marshall C.Watson, 1800 N.W. 49™ Street, Suite 120 Fort Lauderdale, FL 33309 (954) 453-0365 Telephone: (800) 441-2438 (95 771-605 mailing list by mail this P.A. Facsimile: By: Mark Alivera, Esq. Bar Number: 0022817 DEFAULT A Default is hereby entered in this action against the Defendants TODD J. MCNALLY, SUZANNE TOALE, SUNTRUST BANK and JOHN DOE N/K/A KAREEM SUWAITY for failure to serve or file any paper as required by law. day of WITNESS my hand and seal of said Court this , 2007 Karen E. Rushing As Clerk of the Court By As Deputy Cler 7 ViO J 4 PN y3 itiwnwn S Td 81 d3s £002 09 I! 040934 YO4 Oat 9€ 07-10313MAILING LIST Case No.: 2007-CA-007980-SC TODD J. MCNALLY 1400 RIDGEWOOD LANE SARASOTA, FL 34231 HUGH C. FERRELL, ESQ. ATTORNEY FOR JONATHAN COOLEY 4924 HIDDEN OAKS TRAIL SARASOTA, FL 34232 SUNTRUST BANK 200 SOUTH ORANGE AVENUE, TOWER 9 ORLANDO, FL 32801 SUZANNE TOALE 1638 SOUTH DR SARASOTA, FL 34239-5037 JOHN DOE N/K/A KAREEM SUWAITY 1412 RIDGEWOOD LANE SARASOTA, FL 34231 UNKNOWN TENANT AT 1412 RIDGEWOOD LANE SARASOTA, FL 34231 07-10313cE ProVest,LLC. __-07-10313 SA802472 4520 Seeding Circle, Tampa, Florida -- 33617 -- (813) 877-2844 - Fax (813) 739-3800 AFFIDAVIT OF SERVICE IN THE CIRCUIT COURT OF SARASOTA COUNTY, FLORIDA PLAINTIFF SUNTRUST BANKBTC, ET. AL, VS. DEFENDANT TODD J. MCNALLY ET AL ET. AL, DEFENDANT TO BE SERVED: TODD J. MCNALLY rer CASE NO 2007-CA-007980-SC TYPE OF PROCESS (x) SUMMONS & COMPLAINT (x) LIS PENDENS DIVISION A ( } OTHER Received this process on the 07/13/2007 at 10:00 AM I (x)served ( )notserved the within named defendant. DATE/TIME: 7/26/2007 6:45:00 PM ADDRESS WHERE 1400 RIDGEWOOD LANE SERVED SARASOTA, FL 34231 (OR ATTEMPTED (x) INDIVIDUAL SERVICE: By delivering to the within named defendant a true copy of this process with the date and hour of service endorsed by mm and, at the same time I delivered to the within sained defendant a copy of the compiaint. (x) Military Status: ( ) Refused (x) No ( ) Yes Branch: (x) Marital Status: ()Refused , (x) Not married ( ) Married ( ) Married, but separated (x) Mobile Home = (_) Yos/VINNot Visible (2) No ( ) Yes Vin: COMMENTS: THE DEFENDANT WAS SERVED AND CURRENTLY RESIDES AT THE SKIPPED SECOND ADDRESS ABOVE. I hereby certify that I am pot g party to the above action or suit and { am over the age of 18 years and the above affidavit is true and correct. "Under penalties ¢ perjury | deglare that [ have read cue rorecoige? Cocamen od that the facts stated im fi ars rae.” ¥.8, 92,5 . t MPA ELE Sworn fo and Subscribed before me this / day Certified Process Server #297 TOM LOVELL County SARASOTA NOTARY PUBLIC ERVER PERSONALLY KNOWN TO ME { )SERVER PRODUCED AS id wise, Sheila Lane Sere, £3" Pecommirsion #00800933 Sete SF expires: OCT. 30, 2010 “BOE RES www. AARON N OTARY.comAFFIDAVIT OF SERVICE Lo, a | eee . SMe ob FLORIDA County of SARASOTA Circuit Cajurt Case Number: 2007 CA 007980 NC Plaintiff: . SUNTRUST BANK VS. Defendant: TODD J. MCNALLY, ET AL. For: PROVEST, INC. 4520 Seedling Circle Tampa, FL 33614 Received by ANDREWS AGENCY on the 17th day of July, 2007 at 10:20 am to be served on SUNTRUST BAN C/O REGISTERED AGENT, 200 S. Orange Ave., TOWER 9, ORLANDO, FL 32801. |, J.N. MEADOWS, being duly sworn, depose and say that on the 18th day of July, 2007 at 4:00 pm, f: Served the within named corporation by delivering a true copy of the SUMMONS: PERSONAL SERVICE ON NATURAL PERSON, NOTICE OF LIS PENDENS, COMPLAINT, EXHIBITS with the date and hour of service endorsed thereon by me to GINA REGAN as PARALEGAL AUTHORIZED TO ACCEPT IN THE ABSENCE THE R.A. of the within named corporation, in compliance with State Statutes. | certify that | am over the age of 18 and have no interest in the above action. 736-B North Magnolia Avenue Orlando, FL 32803 (407) 649-2085 Our Job Serial Number: 2007025164 Ref: M07-10313 Service Fes: Copyright @ 1992-2006 Database Services, Inc. - Process Server's Toolbox V8.1¢res ng il ProVest,LLC. —#-07-10313 SABIZ 4520 Seeding Circle, Tampa, Florida — 33617 — (813) 877-2844 - Fax (813) 739-3800 AFFIDAVIT OF SERVICE IN THE CIRCUIT COURT OF SARASOTA COUNTY, FLORIDA PLAINTIFF SUNTRUST BANKETC., ET. AL., ¥S. DEFENDANT TODD J. MCNALLY ET AL ET. AL., DEFENDANT TO BE SERVED: SUZANNE TOALE CASE NO 2007-CA-007980-SC TYPE OF PROCESS (x) SUMMONS & COMPLAINT (x) LIS PENDENS DIVISION A ( ) OTHER Received this process on the 07/18/2007 at £0:00 AM I (x)served ( )notserved = the within named defendant. DATE/TIME: 8/2/2007 4:45:00 PM ADDRESS WHERE 1638 SOUTH DR SERVED SARASOTA, FL 34239-5037 (OR ATTEMPTED) (x) INDIVIDUAL SERVICE: By delivering to the within named defendant a true copy of this process with the date and hour of service endorsed by and, at the same time I delivered to the within named defendant a copy of the complaint. (x) Military Status: ( ) Refused (x) No () Yes Branch: (x) Marital Status: ( ) Refused §®) Not married ( ) Married { } Married, but separated (x) Mobile Home ( )Yes/VINNot Visible (x) No ( > Yes Vin: COMMENTS: | hereby certify that I am not a party to the above action or suit and | am over the age of 18 years and the above affidavit is true and correct. “Under penalties of neriury, Litecian “7 Yea the foregoing document and that the facts stated in ¢ are tree,” F ~. i) feat iy" Xx (pee FPS EA. oy Sworn to and Subscribed Certiffed Pracess Server #297 TOM LOVELL County SARASOTA NOT, (SERVER PERSONALLY KNOWN TO ME (.) SERVER PRODUCED AS id s sare 4 Lasts ont 30, 2010 ake www. AARONNOTARY com“ Na ProVest, LLC. —#07-10313 4520 Seeding Circle, Tampa, Florida -- 33617 ~ (813) 877-2844 - Fax (813) 739-3800 AFFIDAVIT OF SERVICE IN THE CIRCUIT COURT OF SARASOTA COUNTY, FLORIDA PLAINTIFF SUNTRUST BANKETC., ET. AL., VS. DEFENDANT TODD J, MCNALLY ET AL ET. AL., DEFENDANT TO BE SERVED: JOHN DOE CASE NO 2007-CA-007980-SC TYPE OF PROCESS (x) SUMMONS & COMPLAINT (x) LIS PENDENS DIVISION A ( ) OTHER Received this process on the 07/13/2007 at 10:00 AM 1 (x)served ( }notserved the within named defendant. DATE/TIME: 7/26/2087 6:45:00 PM ADDRESS WHERE 1412 RIDGEWOOD LANE SERVED SARASOTA, FL 34231 (OR ATTEMPTED) (x) INDIVIDUAL SERVICE: By delivering to the within named defendant a true copy of this process with the date and hour of service endorsed by tie, and, at the same time I delivered to tho within named defendant @ copy of thy complaint. { ) Military Status: ( ) Refused { }No ( ) Yes Branch: ( ) Marital Status: ( ) Refused ( )} Not married ( ) Married { } Mamied, but separated (x) Mobile Home = (_) Yes/VIN Not Visiblc (x) No ( ) Yes Vin: COMMENTS: JOHN DOE IS N/K/A KAREEM SUWAITY. I hereby certify that ] am not a party to the above action or suit and I at over the age of 18 years and the above affidavit is true and coprest. *"Elnde: ies of perjury, I decizre that I havefeatthe forecoine dac RY and that ¢i i's stated in roe," Pibonda - %. Oy? 0 x ple Soe Riet Sworn to and Subscribed before me this 7 day o Certificd Process Server #297 TOM YOVELL County SARASOTA NOTARY PUBLI oaven PERSONALLY KNOWN TO ME ( }SERVER PRODUCED AS id ee . Sheila Lane $5" A, See commission #00008893 Sees expires: OCT. 30, 2010 UES ww, AARONNGTABY.com t