Reply to Affirmative Defenses - Luis Moreno, et al Plaintiff vs. Banta Properties, Inc.,, et al Defendant

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On October 19, 2020 a neg - premises liability residential case was filed by Moreno, Luis, and Ramos, Mary Beatrice, represented by Share, Stuart H, against Banta Properties, Inc.,, and Colonial Park Apartments, Llc, represented by Mccardle, Patrick Colin, in the jurisdiction of Broward County. Judge Frink, Keathan B. presiding.

                        
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                          Filing # 121623721 E-Filed 02/18/2021 11:32:42 AM

IN THE CIRCUIT COURT OF THE 17"
DISTRICT IN AND FOR BROWARD
COUNTY, FLORIDA

GENERAL JURISDICTION DIVISION

CASENO:  CACE-20-017319
LUIS MORENO and MARY BEATRICE
RAMOS, a married couple,

Plaintiffs,
vs.

BANTA PROPERTIES, INC., a Florida Profit
Corporation, and COLONIAL PARK
APARTMENTS, LLC, a Florida Limited Liability
Company,

Defendants.
/

 

PLAINTIFFS’ REPLY TO DEFENDANTS’
ANSWER AND AFFIRMATIVE DEFENSES

Plaintiffs, by and through their undersigned counsel, hereby file their reply to Defendants
BANTA PROPERTIES, INC. and COLONIAL PARK APARTMENTS, LLC’S Affirmative
Defenses and state:

1. Plaintiffs deny each and every affirmative defense set forth by the Defendants in their

Answer to the Complaint dated October 19, 2020 and demands strict proof thereof.

CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the above and foregoing was E-Filed and E-
Mailed this 18" day of February 2021 to: Genevieve P. Rupelli, Esq. an…