16-2024-CC-005557-AXXX-MA Div: CC-D
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`Filing # 195194534 E-Filed 04/01/2024 01:47:28 PM
`IN THE COUNTY COURT OF DUVAL COUNTY
`STATE OF FLORIDA
`CIVIL DIVISION
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`
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`Florida Land Trust Agreement No GT4236
` Plaintiff,
`vs.
`
`
`Gloria Coon
` Defendant(s)
`______________________________________/
`
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`Case No. ______________________
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`COMPLAINT
`(For Tenant Eviction)
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` The Plaintiff Florida Land Trust Agreement No GT4236 by and through undersigned counsel,
`hereby sues Defendant(s), Gloria Coon, hereinafter the “Defendant”, and alleges:
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`1. This is a cause of action to evict the Defendant from residential real property, in DUVAL
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`County, Florida.
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`2. The Plaintiff owns or is the Lessor of the following described real property:
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`2854 W. 9th St., Jacksonville, FL 32254
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`3. Defendant has possession as Lessee of the property under a written lease agreement, a copy
`of which is attached hereto as Exhibit “A.”
`4. The base monthly rental rate Defendant owes to Plaintiff is $975.00. The Defendant failed
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`to pay the full rent due for March 2024 and all subsequent monthly rent payments. Defendant
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`currently owes Plaintiff $1,814.00 through April 30, 2024.
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`5. On March 20, 2024 he Plaintiff served the Defendant with a written notice to pay the past
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`due rent or surrender possession of the property to the Plaintiff, a copy of which is attached hereto
`as Exhibit “B.”
`6. Defendant shall owe all rents accruing during the pendency of this action.
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`7. The Defendant failed to pay the past due rent or surrender possession of the property to the
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`Plaintiff.
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`8. Pursuant to §83.59(2), Florida Statutes, the Plaintiff is entitled to summary procedure as
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`provided for under §51.011, Florida Statutes.
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`9. All conditions precedent necessary to this cause of action have occurred, been performed,
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`or waived.
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`10. Plaintiff has retained the undersigned counsel to represent it in this action and has agreed
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`to pay counsel a reasonable fee for their services.
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`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 04/03/2024 06:42:59 AM
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` WHEREFORE, Plaintiff demands judgment for possession of the premises, costs and
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`attorney's fees under Florida Statute 83.48.
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`LAW OFFICES OF HEIST, WEISSE & WOLK, PLLC
`ATTORNEY FOR PLAINTIFF
`P.O. BOX 62884
`FORT MYERS, FL 33906
`tel: 800-253-8428
`fax: 800-367-9038
`Email: pleadingsjw@evict.com
`
`By: /s/ Jeffery M. Wilkins
`
`Fl. Bar #559911
`
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`NOTICE REQUIRED BY THE FAIR DEBT COLLECTION PRACTICES ACT
`15 U.S.C. 1692 et seq.
`1. This lawsuit is an attempt to collect a debt and any information obtained will be used for
`that purpose.
`2. The amount of the debt that you owe is listed in the lawsuit attached herewith.
`3. Unless you dispute the validity of the debt within thirty (30) days of this letter, this firm
`will assume the debt is valid.
`4. If you notify this firm in writing within the thirty-day period that the debt or any portion
`thereof, is disputed, this firm will obtain verification of the debt and mail you a copy of
`same.
`5. Upon your written request within the thirty-day time period, this firm will provide you
`with the name and address of the original creditor, if different from the current creditor.
`6. Requests for verification and/or the address of a new creditor should be sent to Law
`Offices of Heist, Weisse & Wolk, PLLC, PO Box 62884, Fort Myers, FL 33906.
`NOTE: This notice to you does not change or extend the time periods set forth in the
`summons for answering the Complaint for eviction.
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`

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`EXHIBIT A
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`01/27 / 2023
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`DATE
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`

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`THREE DAY NOTICE
`TO PAY RENT OR DELIVER POSSESSION
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`March 20, 2024
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`to: Gloria Coon
`2854 W 9th Street
`Jacksonville, FL 32254
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`YOU ARE HEREBY NOTIFIED THAT YOU ARE INDEBTED TO US IN THE SUM OF
`$839.00
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`FOR THE RENT AND USE OF THE ABOVE REFERENCED PREMISES IN DUVAL COUNTY, FLORIDA, NOW
`OCCUPIED BY YOU AND THAT WE DEMAND PAYMENTOF SAID RENT OR THAT YOU SURRENDER
`POSSESSION OF THE SAID PREMISES WITHIN THREE(3) DAYS (EXCLUDING SATURDAYS, SUNDAYS, AND
`LEGAL HOLIDAYS) FROM THE DATE OF DELIVERY OF THIS NOTICE:
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`ON OR BEFORETHE25th day of March 2024.
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`YOUR FAILURE TO COMPLY WITH THIS NOTICE MAY RESULTIN EVICTION PROCEEDINGS BEING
`INSTITUTED AGAINST YOU PURSUANT TO SECTION 83 FLORIDA STATUTES.
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`Cheryl Owens Efpir Cyutre
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`Agent Signature and Printed Name
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`ProSource Realty Inc.
`Management Company Name
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`101 Union St E Suite 403
`Management Company Address
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`904-350-2097
`Telephone Number
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`CERTIFICATE OF SERVICE
`| hereby certify that a copy of the above notice was:
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`delivered to
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`by hand.
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`(Tenant's name)
`_posted on the premises described abovein the tenant’s absence.
`on Mauh 22
`,20.2¢.
`or(!~Agent Signature
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`OR
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`\
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`Because of the global COVID-19 pandemic, you maybeeligible for temporary protection from
`eviction under Federal law. Learn the steps you should take now: Visit www.cfpb.govieviction
`Or call a housing counselor at 800-569-4287
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`EXHIBIT B
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