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IN THE CIRCUIT COURT IN AND
FOR ST. LUCIE COUNTY, FLORIDA.
CASE N0. 76-895-CA
LIBERTY LIFE INSURANCE COMPANY,
a South Carolina Corporation, -
Plaintiff,
vs.
ST. LUCIE ENTERPRISES, INC., a
Florida Corporator, LUCILLE V. COSTA,
GEORGE A. COSTA, FIRST NATIONAL BANK
OF FORT PIERCE, FLORIDA, BEARS NEST, a
New Jersey Corporation, ASSOCIATED INNS,
INC., ESCAMBIA INSS OF DOTHAN, INC., SANTA
ROSA INNS, INC., ESCAMBIA INNS, INC., and
ETOWAH ENTERPRISES, INC.,
Defendants.
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STIPULATED MOTION TO DISMISS
DEFENDANT, FIRST NATIONAL BANK OF FORT PIERCE
AND TO DISMISS CROSSCLAIM
OF FIRST NATIONAL BANK OF FORT PIERCE
THE PARTIES HERETO by and through their- respective
undersigned counsel move this Court to enter an Order dis- -
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missing the Complaint filed herein as to Defendant, First
National Bank of Fort Pierce and to dismiss the Crossc-laim
of First National Bank of Fort Pierce filed herein and as
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j grounds therefor would show unto this Court that this Court
t once again has jurisdiction over this cause due to the
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I fact that the United States District Court For the District
E of New Jersey has entered an Order releasing the Stay Order
as to the real property which is the subject matter of
this action and would further show unto this Court that for
valuable consideration received by it, said Defendant, First
National Bank of Fort Pierce has executed and filed a
a
Partial Release of its mortgage as to the real property which
is the subject matter of this cause.
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WHEREFORE, all parties request this Court to
enter an .Order granting the relief prayed for herein
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C ar es R. Brown, Esquire - onet, Esquire
~ P. 0. Box 1418 Suit 0, Hartford Building ?
- Ft. Pierce, FL 33450 200 E. Robinson St.
Attorney for First National Orland FL 32801
Bank of Fort Pierce Attor ey for Liber Life ~
Charles R_ clCinnon tt M. Kenney, Esq '
[ ~ - s. _ r__ r.~MA