On October 15, 2019 a
Motion to Appear Telephonically - ON MARCH 31, 2020 AT 8:30A.M / EX-PARTEParty: Plaintiff Smith, Lueretta
was filed
involving a dispute between
Smith, Lueretta,
and
Winn- Dixie Stores, Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
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Filing # 105036502 E-Filed 03/17/2020 04:20:51 PM
IN THE CIRCUIT COURT OF THE
17™ JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO: CACE 19-021319
Lueretta Smith, individually,
Plaintiff,
VS.
Winn-Dixie Stores, Inc., a Florida corporation,
Defendant.
/
PLAINTIFF’S EX-PARTE MOTION TO ATTEND THE HEARING ON MARCH
31, 2020 AT 8:30A.M. TELEPHONICALLY
Plaintiff, by and through undersigned counsel, requests an Order allowing Plaintiff to
attend the above-titled Motions scheduled for March 31, 2020 at 8:30A.M. telephonically, and
states as follows:
1. This is an action for premises liability for a slip and fall.
2. Defendant, Winn-Dixie Stores, Inc.’s Motion for Protective Order Regarding In-Store
Surveillance Video and Plaintiff's Motion to Compel Incident Video, more detailed
Privilege Log, and to Overrule Objections to Discovery is set for hearing on 03/31/2020 at
8:30A.M.
3. Said Motions are non-complex motions.
4. The undersigned counsel is located in Weston, Florida. Due to the national pandemic, we
are respectfully requesting leave for undersigned counsel for Plaintiff to appear
telephonically.
5. Plaintiff does not object if any of the parties wish to appear telephonically.
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/17/2020 04:20:51 PM.****6. The undersigned counsel will call Court Call at the following toll-free number 1-888-
882-6878 to schedule the telephonic appearance.
WHEREFORE, Plaintiff requests this Court enter an Order allowing Plaintiff to
attend to the above titled hearing telephonically.
CERTIFICATE OF SERVICE
I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at
pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on March 17, 2020.
Law Offices of Justin G. Morgan, P.A.
2500 Weston Road, Suite 211
Weston, Florida 33331
Tel: (954) 217-1016
Fax: (954) 217-1019
pleadings@justinmorganlaw.com
/s/ Susan Guller, Esq.
SUSAN GULLER, ESQ.
F.B.N.: 385859
Document Filed Date
March 17, 2020
Case Filing Date
October 15, 2019
Category
Neg - Premises Liability Commercial
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Filing # 105036502 E-Filed 03/17/2020 04:20:51 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 19-021319 Lueretta Smith, individually, Plaintiff, VS. Winn-Dixie Stores, Inc., a Florida corporation, Defendant. / PLAINTIFF’S EX-PARTE MOTION TO ATTEND THE HEARING ON MARCH 31, 2020 AT 8:30A.M. TELEPHONICALLY Plaintiff, by and through undersigned counsel, requests an Order allowing Plaintiff to attend the above-titled Motions scheduled for March 31, 2020 at 8:30A.M. telephonically, and states as follows: 1. This is an action for premises liability for a slip and fall. 2. Defendant, Winn-Dixie Stores, Inc.’s Motion for Protective Order Regarding In-Store Surveillance Video and Plaintiff's Motion to Compel Incident Video, more detailed Privilege Log, and to Overrule Objections to Discovery is set for hearing on 03/31/2020 at 8:30A.M. 3. Said Motions are non-complex motions. 4. The undersigned counsel is located in Weston, Florida. Due to the national pandemic, we are respectfully requesting leave for undersigned counsel for Plaintiff to appear telephonically. 5. Plaintiff does not object if any of the parties wish to appear telephonically. *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 03/17/2020 04:20:51 PM.****6. The undersigned counsel will call Court Call at the following toll-free number 1-888- 882-6878 to schedule the telephonic appearance. WHEREFORE, Plaintiff requests this Court enter an Order allowing Plaintiff to attend to the above titled hearing telephonically. CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on March 17, 2020. Law Offices of Justin G. Morgan, P.A. 2500 Weston Road, Suite 211 Weston, Florida 33331 Tel: (954) 217-1016 Fax: (954) 217-1019 pleadings@justinmorganlaw.com /s/ Susan Guller, Esq. SUSAN GULLER, ESQ. F.B.N.: 385859