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
Filing # 102714278 E-Filed 02/04/2020 12:41:16 PM
IN THE CIRCUIT COURT IN AND FOR WALTON COUNTY, FLORIDA
FAMILY LAW DIVISION
ASSOCIATION PARTNERS, LLC,
Plaintiff,
v. Case No.: 2019 CA 000410
WILLIAM D. PAYNE AND LOIS E. PAYNE
HUSBAND AND WIFE,
Defendants.
PLAINTIFF’S MOTION TO DISMISS DEFENDANTS MOTION TO STRIKE AND
MOTION TO ALLOW COUNSEL FOR THE PLAINTIFF TO APPEAR
TELEPHONICALLY
COMES NOW the Petitioner, ASSOCIATION PARTNERS, LLC, by and through the
undersigned attorney, and moves this Court for an order allowing Plaintiff's Motion to Dismiss
Defendants Motion to Strike and Motion to Appear Telephonically at the upcoming hearing as
follows:
1. The Defendant filed a Motion to Strike Complaint alleging the Plaintiff must be
represented by counsel.
2. The Plaintiff subsequently filed a Notice of Appearance on October 16, 2019.
3. The appearance of counsel cures any alleged deficiencies.
4. The counsel for the Plaintiff has contacted current counsel for the defendant and
has been informed by the counsel they intend to withdraw and therefore is unable
to specify the Defendant’s position.
5. Should it be necessary for counsel to appear as this is a non-evidentiary speaking
motion and counsel for the plaintiff's office is located in Pensacola, Florida.
Therefore, counsel respectfully requests he be allowed to appear by telephone
WHEREFORE, the Defendant be required to file an answer within 10 day of the order.
Electronically Filed Walton Case # 19000410CAAXMX 02/04/2020 11:41:16 AMShould the court require a hearing that counsel for the Plaintiff be allowed to appear telephonically
and grant such other relief as the court deems meet and just.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a copy of this document was electronically filed via the
Florida Courts E-filing Portal and served to Mitch Dever, Esquire, P.O. Box 9811, Panama City
Beach, Florida 32417, at mitchdever@comeast.net on this 31 day of January, 2020.
GF/art
[| Gregory 2. Far
GREGORY P. FARRAR (FBN 708860)
FARRAR LAW FIRM AND MEDIATION GROUP
109 N. Palafox Street
Pensacola, Florida 32502
Phone (850) 434-8904
Fax (850) 434-8922
Attorney for: Petitioner
efile@farrarlawfirm.com;
aturmer@farrarlawfirm.com:;
rdugas@farrarlawfirm.com
Document Filed Date
February 04, 2020
Case Filing Date
August 27, 2019
Category
Circuit Civil 3-D
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Filing # 102714278 E-Filed 02/04/2020 12:41:16 PM IN THE CIRCUIT COURT IN AND FOR WALTON COUNTY, FLORIDA FAMILY LAW DIVISION ASSOCIATION PARTNERS, LLC, Plaintiff, v. Case No.: 2019 CA 000410 WILLIAM D. PAYNE AND LOIS E. PAYNE HUSBAND AND WIFE, Defendants. PLAINTIFF’S MOTION TO DISMISS DEFENDANTS MOTION TO STRIKE AND MOTION TO ALLOW COUNSEL FOR THE PLAINTIFF TO APPEAR TELEPHONICALLY COMES NOW the Petitioner, ASSOCIATION PARTNERS, LLC, by and through the undersigned attorney, and moves this Court for an order allowing Plaintiff's Motion to Dismiss Defendants Motion to Strike and Motion to Appear Telephonically at the upcoming hearing as follows: 1. The Defendant filed a Motion to Strike Complaint alleging the Plaintiff must be represented by counsel. 2. The Plaintiff subsequently filed a Notice of Appearance on October 16, 2019. 3. The appearance of counsel cures any alleged deficiencies. 4. The counsel for the Plaintiff has contacted current counsel for the defendant and has been informed by the counsel they intend to withdraw and therefore is unable to specify the Defendant’s position. 5. Should it be necessary for counsel to appear as this is a non-evidentiary speaking motion and counsel for the plaintiff's office is located in Pensacola, Florida. Therefore, counsel respectfully requests he be allowed to appear by telephone WHEREFORE, the Defendant be required to file an answer within 10 day of the order. Electronically Filed Walton Case # 19000410CAAXMX 02/04/2020 11:41:16 AMShould the court require a hearing that counsel for the Plaintiff be allowed to appear telephonically and grant such other relief as the court deems meet and just. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of this document was electronically filed via the Florida Courts E-filing Portal and served to Mitch Dever, Esquire, P.O. Box 9811, Panama City Beach, Florida 32417, at mitchdever@comeast.net on this 31 day of January, 2020. GF/art [| Gregory 2. Far GREGORY P. FARRAR (FBN 708860) FARRAR LAW FIRM AND MEDIATION GROUP 109 N. Palafox Street Pensacola, Florida 32502 Phone (850) 434-8904 Fax (850) 434-8922 Attorney for: Petitioner efile@farrarlawfirm.com; aturmer@farrarlawfirm.com:; rdugas@farrarlawfirm.com