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IN THS CIRCUIT COURT OF THL~ ~
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' NINETESNTH JUDICIAL CIRCUIT `
~~y~ OF FLORIDA, IN AND FOR ST.
LLICIE COUNTY, FLORIDA.
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CASE NO. 75-815 CA
IRA M. MCALPIN and JENNIE H. MCALPIN *
his wife, ~
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Plaintiffs,
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-vs-
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C. D. CLTMENTS al'td LUCY CLBMBNTS,
his wife; VENDSLA C. GOODWIN WOODY; *
R. R. GOODWIN; EVERETT TRACY and •
SHIRLEY TRACY, as survivinq *
Directors and Trustees of AMSRICAN
PLUMBING & HEATING CO., INC., a * .
dissolved Florida Corporation, `
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Defendants.
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MOTION FOR DEFAULT
CONIS NOW, the Plaintiffs, IRA M. MCALPIN.and JENNIE H. MCALPIN,
his wife, and would shaw unto the Court that the Defendants, C. D.
CLEMENTS and LUCY CLEA~NTS, his wife; VENDELA C. GOODiWIN WOODY; and
R. R. GOODWIN were duly served with process in this cause on the Sth
day of August, 1975 by a Deputy ~heriff of the Office ot the ~t. -
Lucie eounty Sheriff's Department; and Defendants, EVERETT TRACY and
SHIRLEY TRACY, as surviving Directors and Trustees of AMERICAN
PLUMBING & HEATING CO., INC., a dissolved Florida Corporation were
duly served with process in this cause on the 6th day of August, 1975
! by a Deputy Sheriff of the Office of the Indian River County Sheriff's
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~ Department; that the time for filing of any answer or other defensive
~ pleading in the cause has nvw expired, and that no answer or other
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defensive pleading has been served upon the law firm of Law Offices
of Charles R. P. Brown, P. O. Box 1418, Fort Pierce,~Florida, attorneys
of record for Plaintiffs herein b~ Defendants, C. D. CLEMENTS and LUCY
CLEMENTS, his wife; VENDELA C. GOODWIN WOODY; R. R. GOODWIN; and
~ EVERETT TRACY and SHIRLEY TRACY, as surviving Directors and Trustees
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of AMERICAN PLUI?iBING & HEATING CO., INC., a dissolved Florida Corpora-
~ tion, or any counsel o~C attorney in their behalf as of the date of this
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~ Motion.
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- ~ a~x 243
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