IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF FLORIDA

GAINESVILLE DIVISION

TRUST FINANCIAL, A MORTGAGE )

COMPANY, LLC, a Texas Limited )

Liability Company )

)

Plaintiff, )

)

vs. ) CASE NO: 1:10-CV-00049-SPM-GRJ

)

FORT ATKINSON PLANTATION, LLC, )

a Florida Limited Liability Company, )

OWEN B. LOVEJOY, an Individual, FRED )

J. HATFIELD, III, an Individual, MARVIN )

BUCHANAN, an Individual, SHERROD )

CAMPBELL, an Individual and CHARLES )

SHERWOOD, )

)

)

Defendants. )

MOTION FOR SUMMARY JUDGMENT BY PLAINTIFF

Plaintiff moves the Court to enter, pursuant to Rule 56 of the Federal Rules of Civil 

Procedure, and 56.1 of the Local Rules for the United States District Court for the Northern 

District of Florida, a summary judgment in Plaintiff’s favor for the relief demanded in its 

complaint and for grounds of its motion says that there is no genuine issue as to any material fact 

and that the Plaintiff is entitled to a judgment as a matter of law.

This motion is based upon the pleadings and exhibits attached thereto, the exhibits

described in the Exhibit List, attached to this motion as Exhibit “A,” deposition excerpts of 

Defendants, Sherwood, Campbell and Lovejoy, attached hereto and Exhibits “B,” “C,” and “D,” 

respectively, the Affidavits of Craig Blackwell, Jack Dollins, Robert P. Reynolds, and Richard S. 

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CASE NO: 1:10-cv-00049-SPM-GRJ

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Petermann, true and correct copies of which are attached to this motion as Exhibits, “E,” “F,” 

“G,” and “H,” respectively, and the letter from counsel for Fort Atkinson, Fred Hatfield, and 

Marvin Buchanan, attached to this motion and identified in the Exhibit List as Exhibit “1.”

WHEREFORE, Plaintiff Trust Financial respectfully requests the Court grant its Motion 

for Summary Judgment on the grounds that there is no genuine issue as to any material fact and 

that the Trust Financial is entitled to a judgment as a matter of law.

Dated this 28th day of January, 2011.

OF COUNSEL

Reynolds, Reynolds, and Duncan, LLC

2115 Eleventh Street

Tuscaloosa, Alabama

P: 205-391-0073

rreynolds@rrdlaw.com

/s/ Robert P. Reynolds____________

Robert P. Reynolds

REYNR4202

Attorney for Plaintiff, Trust

Financial, A Mortgage Company, LLC

OF COUNSEL

Richard S. Petermann

Florida Bar No. 362956

/s/ Jeffrey L. Burns

Florida Bar No. 40782

Anchors Smith Grimsley

909 Mar Walt Drive, Suite 1014

Fort Walton Beach, FL 32547

P: 850-863-4064

rppertermann@asglegal.com

jburnes@asglegal.com

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the above and foregoing was 

furnished by electronic and/or U.S. Mail to Andrew J. Decker, III, Esq., ATTORNEY FOR 

FORT ATKINSON PLANTATION, LLC, FRED J. HATFIELD, III and MARVIN 

BUCHANAN, P.O. Box 1288 Live Oak, FL 32064, and, Kristin M. Davis, Esq., and Peter 

Robertson, Esq. ATTORNEYS FOR SHERROD CAMPBELL, OWEN B. LOVEJOY and 

CHARLES SHERWOOD, 5216 SW 91st Dr., Suite 10, Gainesville, FL 32608, this 28th day of 

January, 2011.

/s/ Robert P. Reynolds_____________

Robert P. Reynolds

Attorney for Plaintiff, Trust

Financial, A Mortgage Company, LLC

Motion.Summary.Judgment.1093.0003.doc

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