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IN THE CIRCUIT COURT, IN AND FOR
ST. LUCIE COUNTY, FLORIDA.
CAS~. NO. IIO-317 CA
MAE WALKER FRANKLIN,
Plaintiff,
vs.
DALE M. NORWOOD, R& R CITRUS
and FLORIDA FARM BUREAU INSURANCE
COMPANY,
Defendant.
MOTION FOR DEFAULT
MAE ~VALY.ER FRANKLIN, Plaintiff, by her undersiqned attorney, .
moves the Clerk of the Court to enter a Default aqainst the following
named Defendants and for good cause would show as follows:
l. Service of process was made on June 16, 1980 at 2:58 a.m.
uoon DALE M. NORWOOD, as will be seen by the return of service filed
by the Secretary of State.
2. Sheriff's service was perfected by the Sheriff of St. Lucie
County, Florida upon R& R CITRUS, a corporation, by serving its
president, as was seen by the original service of process filed in this
cause.
3. That the Defendant, R& R CITRUS, a corporation, is not in
the military service because corporations are ineligible for military
service.
WHEREFORE, it is requested that an immediate default be entered
against the Defendant, R& R CITRUS, a cor~oration, for its failure to
respond to service of process by the Sheriff as required by law.
McDONALD, GONANO & ASSOCIATES, P.A.
Suite 200, Citizens Federal Bldg.
1600 S. Federal Highway
Fort Pie e Florida 33450
Attorn s Plaintiff
By
C. R. cDonald, Jr.
gao 351 ~~~E 1~0