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Renewed Motion To Dismiss For Lack of Subject Matter Jurisdiction
Renewed Motion To Dismiss For Lack of Subject Matter Jurisdiction
CETEIAL BAK,
Defendants.
____________________________________
JOH CARROLL,
Counter-Plaintiff
vs.
Counter-Defendants.
____________________________________________/
Rule of Civil Procedure 1.140(b)(1) and 1.140(h)(2) moves for an Order Dismissing
jurisdiction has not been established in Coastal’s First Amended Complaint. The
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jurisdictional question can be raised at any time and can never be time-barred, Florida
insomuch as no specific facts have been alleged which determine whether or not Coastal
or Centennial are a Corporation, LLC, LLP, etc. and if so, whether or not Coastal or
exists Cunningham v. Standard Guar. Ins. Co., 630 So 2d 179 (Fla 1994) In re D.N.H.W.,
955 So 2d 1236 (Fla 2d DCA 2007); and subject-matter jurisdiction may not be conferred
on court by consent of parties MCR Funding v. CMG Funding Corp., 771 So 2d 32, 35
4. This Court has dismissed similar claims with the right to Amend the
Complaint in HSBC Bank USA, etc. v Boone, Walton County 08 CA 557 and Lasalle
Plaintiff’s First Amended Complaint without Prejudice; and granting such other or
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I HEREBY CERTIFY that a copy of the foregoing was forwarded to Frank A.
Baker, Esq., 4431 Lafayette Street, Marianna, FL. 32446, counsel for Coastal, and to Paul
Alan Sprowls, Asst. U.S. Attorney, 111 North Adams Street, Tallahassee, FL 32301,
counsel for the IRS, and to Mike Byers 12141 Panama City Beach, FL. 32407 by regular
mail this 10th day of September, 2010.
Respectfully submitted,
___________________________
John Carroll
Box 613524
WaterSound, FL 32461
Phone (850) 231-5616
Fax (850) 622-5618