On August 27, 2019 a
Motion,Ex Parte
was filed
involving a dispute between
Association Partners, Llc,
Proctor, Thomas C Sr,
and
Payne, Lois E,
Payne, William D,
for Circuit Civil 3-D
in the District Court of Walton County.
Preview
F
Filing # 96869982 E-Filed 10/07/2019 04:31:27 PM
IN THE CIRCUIT COURT, FIRST JUDICIAL CIRCUIT OF
THE STATE OF FLORIDA, IN AND FOR WALTON COUNTY
ASSOCIATION PARTNERS, LLC,
Plaintiff,
v. CASE NO. 19-410CA
WILLIAM D. PAYNE AND
LOIS E. PAYNE, HUSBAND AND WIFE,
Defendants.
MOTION TO STRIKE COMPLAINT
COME NOW the Defendanis, William D. Payne and Lois E. Payne, by and through
their undersigned counsel, pursuant to the Florida Rules of Civil Procedure, and herewith
files this Motion to Strike Complaint, and as grounds therefor states that the Plaintiff is a
corporate entity ie. LLC; however, the individual that filed this action on behalf of the
Plaintiff is not a licensed attorney
WHEREFORE, Defendants respectfully pray that this Honorable Court enter an
Order granting Defendants’ Motion to Strike and grant such other relief as the Court may
deem just and proper, and awarding all attorney fees and costs.
Dated this 4 day of October, 2019.
Mitch Dever; Ksquire
Florida Bar No. 0939730
P.O. Box 9811
Panama City Beach, FL 32417
Telephone: (850) 234-5555
| Fax: (850) 234-7677
Email: mitchdever@comcast.net
Attorney for Defendants
Electronically Filed Walton Case # 19000410CAAXMX 10/07/2019 03:31:27 PM
-1-CERTIFICATE OF SERVICE
| hereby certify that a copy of the above and foregoing hasbeen furnished by email
to Thomas C. Proctor, Sr., ‘ie Partner of Association Pa peere Box 547,
Tallahassee, Florida 32302, this day of October, 2019
Mitch Dever, Esquire
Document Filed Date
October 09, 2019
Case Filing Date
August 27, 2019
Category
Circuit Civil 3-D
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
F Filing # 96869982 E-Filed 10/07/2019 04:31:27 PM IN THE CIRCUIT COURT, FIRST JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR WALTON COUNTY ASSOCIATION PARTNERS, LLC, Plaintiff, v. CASE NO. 19-410CA WILLIAM D. PAYNE AND LOIS E. PAYNE, HUSBAND AND WIFE, Defendants. MOTION TO STRIKE COMPLAINT COME NOW the Defendanis, William D. Payne and Lois E. Payne, by and through their undersigned counsel, pursuant to the Florida Rules of Civil Procedure, and herewith files this Motion to Strike Complaint, and as grounds therefor states that the Plaintiff is a corporate entity ie. LLC; however, the individual that filed this action on behalf of the Plaintiff is not a licensed attorney WHEREFORE, Defendants respectfully pray that this Honorable Court enter an Order granting Defendants’ Motion to Strike and grant such other relief as the Court may deem just and proper, and awarding all attorney fees and costs. Dated this 4 day of October, 2019. Mitch Dever; Ksquire Florida Bar No. 0939730 P.O. Box 9811 Panama City Beach, FL 32417 Telephone: (850) 234-5555 | Fax: (850) 234-7677 Email: mitchdever@comcast.net Attorney for Defendants Electronically Filed Walton Case # 19000410CAAXMX 10/07/2019 03:31:27 PM -1-CERTIFICATE OF SERVICE | hereby certify that a copy of the above and foregoing hasbeen furnished by email to Thomas C. Proctor, Sr., ‘ie Partner of Association Pa peere Box 547, Tallahassee, Florida 32302, this day of October, 2019 Mitch Dever, Esquire