On September 17, 2012 a
Motion,Ex Parte
was filed
involving a dispute between
H & Lk Llc,
and
Alberts, Nancy,
Alberts, Nathan,
Individualized Educational Services Inc,
for Contract Indebtedness
in the District Court of Clay County.
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E-Filed 10/15/2012 03:08 PM James B. Jett
IN THE CIRCUIT COURT FOR THE FOURTH JUDICIAL CIRCUIT
IN AND FOR CLAY COUNTY, FLORIDA.
H&LK,LLC. CASE NO: 12-CA-1833
a Florida Corporation DIVISION: E
Plaintiff,
Vs.
INDIVIDUALIZED EDUCATIONAL SERVICES, INC.
a Florida Corporation
And NATHAN AND NANCY ALBERTS
Individually
Defendants.
i
MOTION FOR CLERK'S DEFAULT JUDGMENT AND
NON-MILITARY PROOF OF CLAIM - COMPLAINT
COMES NOW, IRVING & REILLY. P.L., as Plaintiff's attorneys and says as follows:
1. That the Defendants, INDIVIDUALIZED EDUCATIONAL SERVICES, INC.,
Corporation. NATHAN ALBERTS, individually, and NANCY ALBERTS, Individually, have failed to file or
serve upon Plaintiff's attorneys, pleadings in the above-captioned cause within the time as prescribed by law,
service of process having been perfected upon the Defendants, INDIVIDUALIZED EDUCATIONAL
SERVICES, INC., NATHAN ALBERTS, and NANCY ALBERTS, on the 25" day of September. 2012.
>
the military service of the United States nor any branch thereof. The Defendants, Individually, are employed
by: Alberts Education Center. 402 Loring Avenue, Orange Park, FL 32073
WHEREFORE, Plaintiff prays this for the entry of a ees against the Defendants
ron J. Irving, Esq/
Attorney for Tne
2. That based upon the information provided to the undersigned, the Defendants, Individually, are not inSTATE OF FLORIDA
COUNTY OF DUVAL
The foregoing Non-military affidavit was subscribed and sworn to before me. a Notary Public. by
AARON J. IRVING, Esq.. who (X) is personally cnown to me and did take an oath, and acknowledged
as his free act and deed this 5 day of © Wye xc 2012.
at oe
Notary Public (Affix notorial seal)
State of Florida
LRA Ki ye
Printed Name
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of this document hereof has been provided by U.S.
Mail to the party listed below this Lip day of {2—m
Document Filed Date
October 15, 2012
Case Filing Date
September 17, 2012
Category
Contract Indebtedness
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E-Filed 10/15/2012 03:08 PM James B. Jett IN THE CIRCUIT COURT FOR THE FOURTH JUDICIAL CIRCUIT IN AND FOR CLAY COUNTY, FLORIDA. H&LK,LLC. CASE NO: 12-CA-1833 a Florida Corporation DIVISION: E Plaintiff, Vs. INDIVIDUALIZED EDUCATIONAL SERVICES, INC. a Florida Corporation And NATHAN AND NANCY ALBERTS Individually Defendants. i MOTION FOR CLERK'S DEFAULT JUDGMENT AND NON-MILITARY PROOF OF CLAIM - COMPLAINT COMES NOW, IRVING & REILLY. P.L., as Plaintiff's attorneys and says as follows: 1. That the Defendants, INDIVIDUALIZED EDUCATIONAL SERVICES, INC., Corporation. NATHAN ALBERTS, individually, and NANCY ALBERTS, Individually, have failed to file or serve upon Plaintiff's attorneys, pleadings in the above-captioned cause within the time as prescribed by law, service of process having been perfected upon the Defendants, INDIVIDUALIZED EDUCATIONAL SERVICES, INC., NATHAN ALBERTS, and NANCY ALBERTS, on the 25" day of September. 2012. > the military service of the United States nor any branch thereof. The Defendants, Individually, are employed by: Alberts Education Center. 402 Loring Avenue, Orange Park, FL 32073 WHEREFORE, Plaintiff prays this for the entry of a ees against the Defendants ron J. Irving, Esq/ Attorney for Tne 2. That based upon the information provided to the undersigned, the Defendants, Individually, are not inSTATE OF FLORIDA COUNTY OF DUVAL The foregoing Non-military affidavit was subscribed and sworn to before me. a Notary Public. by AARON J. IRVING, Esq.. who (X) is personally cnown to me and did take an oath, and acknowledged as his free act and deed this 5 day of © Wye xc 2012. at oe Notary Public (Affix notorial seal) State of Florida LRA Ki ye Printed Name CERTIFICATE OF SERVICE | HEREBY CERTIFY that a true and correct copy of this document hereof has been provided by U.S. Mail to the party listed below this Lip day of {2—m