On July 29, 2005 a
Motion,Ex Parte
was filed
involving a dispute between
Lese, Dennis,
and
Toale, Suzanne,
in the District Court of Sarasota County.
Preview
Re
Ome a
aan BS F&F
DENNIS LESE, see AS
— ~ 7
2 LO
Plaintiff, 262" $
Sask. -2 =D
oO rs ry
v. CASE NO. 2005 CC 4079:NC; ‘2 ©
= = =
SUZANNE TOALE,
Defendant.
/
MOTION TO CONSOLIDATE
Defendant, SUZANNE TOALE, moves to consolidate this action with an action
pending in the Circuit Court for Sarasota County, Florida, styled, Suzanne Toale,
Plaintiff, vs. Dennis Lese and Relish This Hot Dog LLC, a Florida limited liability
company, Defendant, Case No. 2005 A O/a/ 1S NC, and as grounds for this
Motion states:
1. Defendant has raised in this action, a defense based on a
partnership existing between Toale, on the one hand, and Lese and/or Relish This Hot
Dog, LLC, a Florida limited liability company on the other.
2. The Action filed by Toale in Circuit Court is a Declaratory Action to
confirm the establishment of the partnership and its breach by Lese and/or the LLC.
3. There are common issues of law and fact between the two actions.
(itiCERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished by U.S. mail delivery to Theodore D. Parker, Esq., 2033 Main Street, Suite
fo
100, Sarasota, Florida, 34237, this /7 day of December, 2005.
LIVINGSTON, PATTERSON
& STRICKLAND, P.A.
46 North Washington Boulevard, Suite 1
Sarasota, FL 34236
(941) 365-0550
Attorneys for Defendant A
By: pe JAZ o =
John Patterson, Esq.
Florida Bar No. 0120242
W:\Toale\Litigation\motion consolidate.doc
Document Filed Date
December 19, 2005
Case Filing Date
July 29, 2005
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Re Ome a aan BS F&F DENNIS LESE, see AS — ~ 7 2 LO Plaintiff, 262" $ Sask. -2 =D oO rs ry v. CASE NO. 2005 CC 4079:NC; ‘2 © = = = SUZANNE TOALE, Defendant. / MOTION TO CONSOLIDATE Defendant, SUZANNE TOALE, moves to consolidate this action with an action pending in the Circuit Court for Sarasota County, Florida, styled, Suzanne Toale, Plaintiff, vs. Dennis Lese and Relish This Hot Dog LLC, a Florida limited liability company, Defendant, Case No. 2005 A O/a/ 1S NC, and as grounds for this Motion states: 1. Defendant has raised in this action, a defense based on a partnership existing between Toale, on the one hand, and Lese and/or Relish This Hot Dog, LLC, a Florida limited liability company on the other. 2. The Action filed by Toale in Circuit Court is a Declaratory Action to confirm the establishment of the partnership and its breach by Lese and/or the LLC. 3. There are common issues of law and fact between the two actions. (itiCERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. mail delivery to Theodore D. Parker, Esq., 2033 Main Street, Suite fo 100, Sarasota, Florida, 34237, this /7 day of December, 2005. LIVINGSTON, PATTERSON & STRICKLAND, P.A. 46 North Washington Boulevard, Suite 1 Sarasota, FL 34236 (941) 365-0550 Attorneys for Defendant A By: pe JAZ o = John Patterson, Esq. Florida Bar No. 0120242 W:\Toale\Litigation\motion consolidate.doc