CE 940 Main Street (Joe Hills) 07.21.2006 Eakin&Sneed EAKIN PAUL M.EAKIN,P.A.
JEFFREY J.SNEED*
g� SNEED ED TERESA H.ELLIS
(� !: ROBIN H.UPCHURCH
ATTORNEYS AT LAW *BOARD CERII1-lbD
CIVIL TRIAL LAWYER
599 ATLANTIC BOULEVARD.SUITE 4 TELEPHONE:904-247-6565
ATLANTIC BEACH.FL 32233 TELECOPY:904-247-6535
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July 21, 2006
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Mr. Joe Edward Hills
940 Main Street
Atlantic Beach, Florida 32233
340 Begonia Street
Atlantic Beach, Florida 32233
Re: Raymond' s Service Center & Auto Disposal
Raymond Dagley, Jr .
Dear Mr. Hills :
Please be advised that I have the pleasure of representing Raymond
Dagley, Jr. and his business of Raymond' s Service Center & Auto
Disposal..
I am aware that you and Mr. Dagley, Jr. as tenants-in-common own
the property located at Block 119, Atlantic Beach, Section H,
according to the plat thereof recorded in Plat Book 18, Page 34 of
the current public records of . Duval County, Florida by virtue of a
• warranty deed given to both of you and which is dated October 21,
2004 .
I am also aware of the fact that you are not involved in my
client ' s business and in fact do not share a business relationship
with him. If you are under the mistaken assumption that you have
a business relationship with my client, please allow this letter to
serve as written termination of any business relationship you
mistakenly think you enjoy with him.
As you know, you have no license to conduct any business from your
' current address of 340 Begonia Street . In fact, my client holds
the only license to conduct road service/towing, auto
service/repair and junk/salvage yard at that location. You have
been conducting unauthorized and unlicensed business from that
location. for years . I have knowledge that you have misinformed
public officialsthat you were in some way connected to my client ' s
business when in fact, you are not . In point of fact, you have
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COPY
Mr. Joe Edward Hills
July 21, 2006
Page 2
never shared any of the monies derived from your business with my
client, but have continued to run your operations separate and
apart from my client ' s business .
You must cease and desist from misrepresenting to public
officials the fact that you are in business with my client and that
you have the authority to conduct your business under our licenses
from your current location. Your activities are clearly a
violation of the Code of Ordinances of the City of Atlantic Beach
which prohibit people from conducting businesses within the City
limits without proper license . By copy of this letter, I am
notifying Alex Sherrer, Code Enforcement Officer for the City of
Atlantic' Beach of your illegal activities .
In conclusion, you must cease and desist representing to others
that you are associated with our business; you must cease and
desist conducting your business from the present location; you must
remove any and all automobiles and junk from the present location
and remediate the site to its former state .
Please govern yourself accordingly,
Since .= ly --•urs,
Pa -1 M. Eakin
P /tjj
• cc: Alex Sherrer, CEO, City of Atlantic Beach
Raymond Dagley, Jr.