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Filing # 132489889 E-Filed 08/11/2021 03:50:38 PM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT, IN AND FOR
MIAMIDADE COUNTY,ju FLORIDA
JUTA BOIANGIN,
PLAINTIFF,
GENERAL JURISDICTION DIVISION
CASE NO.: 2018-032555-CA-01
v. SECTION: CA 13
BLUE JAY TRUCKING, INC., a Florida
For profit corporation, IMPACT LOGISTICS
SERVICES, LLC, a New Jersey limited company,
and AJA PROPERTIES NO.6 LTD, a Florida
limited partnership,
DEFENDANT.
** PARTIES MAY NOT MUTUALLY
AGREE TO RESCHEDULE. THE
COURT MUST GRANT THE
PARTIES A CONTINUANCE. **
________________________________/
REQUEST FOR SPECIAL SET HEARING BEFORE JUDGE GINA BEOVIDES
Motion for which hearing is requested -full title (Courtesy copy of motion(s) must be attached)
DEFENDANT, AJA PROPERTIES NO. 6 LTD’S MOTION FOR SUMMARY JUDGMENT ___________
Evidentiary (requires testimony) _________ (check this box)
Thirty (30) Minutes Amount of time requested for ALL sides to complete presentation:
Please be advised Judge reads everything delivered in advance.
To be completed by Counsel or Pro Se Litigant:
_____ I certify that a copy of these Motion(s) has been received by the opposing
Counsel or Party.
Check one of below:
__X___ I have conferred with the opposing Counsel or Pro Se party in a good faith effort to
resolve the matter (s) without a hearing and to determine the amount of time
requested for the hearing; or
_____ I have been unable to confer with opposing counsel or pro se party because (state
circumstances):___________________________________________________________
__________________________________________________________________
** All Memoranda or documents for consideration MUST be submitted
7 BUSINESS DAYS IN ADVANCE of Scheduled Special Set Hearing date. **
/s/Charise Morgan-Joseph
CHARISE MORGAN-JOSEPH, ESQ.
Florida Bar #: 102316
charise.morganjoseph@zurichna.com
LAW OFFICE OF MARK C. BURTON
Employees of a Member Company of Zurich Ins. Group
Presidential Circle, Suite 430-N
4000 Hollywood Boulevard
Hollywood, FL 33021
Telephone: (954) 967-6471
E-service: usz.slftl@zurichna.com
Attorneys for Defendant, AJA PROPERTIES NO. 6 LTD
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing and accompanying motions has
been sent via
electronic mail this 11th day of August, 2021, pursuant to the Florida Rules of Civil Procedure to the
following:
Eric M. Tinstman, Esquire, The Tinstman Law Firm, P.A., Attorney for Plaintiffs, 2665 S. Bayshore Drive,
Suite 601, Grand Bay Plaza, Miami, Florida 33133 at eric@thetinstmanlawfirm.com; Ryan M. Clancy,
Esquire, Ainsworth & Clancy, Attorney for Plaintiff, 801 Brickell Ave., 9th Floor, Miami, Florida 33131 at
ryan@business-esq.com; and to: Michael A. Sastre, Esquire and Aaron H. Epstein, Esquire, Sastre
Saavedra & Epstein, Attorney for Blue Jay Trucking, Inc., One S.E. 3rd Avenue, Suite 1280, Miami, Florida
33131 at sastre@sselegal.com; aaron@sselegal.com and maria@sselegal.com.
IMPORTANT NOTE: You must contact the other side prior to requesting a hearing so that
we may assure the issue is, in fact, contested and that the appropriate amount of time is
being set aside. Please contact all sides and only then submit your package.
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Filing # 132489889 E-Filed 08/11/2021 03:50:38 PM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT, IN AND FOR MIAMIDADE COUNTY,ju FLORIDA JUTA BOIANGIN, PLAINTIFF, GENERAL JURISDICTION DIVISION CASE NO.: 2018-032555-CA-01 v. SECTION: CA 13 BLUE JAY TRUCKING, INC., a Florida For profit corporation, IMPACT LOGISTICS SERVICES, LLC, a New Jersey limited company, and AJA PROPERTIES NO.6 LTD, a Florida limited partnership, DEFENDANT. ** PARTIES MAY NOT MUTUALLY AGREE TO RESCHEDULE. THE COURT MUST GRANT THE PARTIES A CONTINUANCE. ** ________________________________/ REQUEST FOR SPECIAL SET HEARING BEFORE JUDGE GINA BEOVIDES Motion for which hearing is requested -full title (Courtesy copy of motion(s) must be attached) DEFENDANT, AJA PROPERTIES NO. 6 LTD’S MOTION FOR SUMMARY JUDGMENT ___________ Evidentiary (requires testimony) _________ (check this box) Thirty (30) Minutes Amount of time requested for ALL sides to complete presentation: Please be advised Judge reads everything delivered in advance. To be completed by Counsel or Pro Se Litigant: _____ I certify that a copy of these Motion(s) has been received by the opposing Counsel or Party. Check one of below: __X___ I have conferred with the opposing Counsel or Pro Se party in a good faith effort to resolve the matter (s) without a hearing and to determine the amount of time requested for the hearing; or _____ I have been unable to confer with opposing counsel or pro se party because (state circumstances):___________________________________________________________ __________________________________________________________________ ** All Memoranda or documents for consideration MUST be submitted 7 BUSINESS DAYS IN ADVANCE of Scheduled Special Set Hearing date. ** /s/Charise Morgan-Joseph CHARISE MORGAN-JOSEPH, ESQ. Florida Bar #: 102316 charise.morganjoseph@zurichna.com LAW OFFICE OF MARK C. BURTON Employees of a Member Company of Zurich Ins. Group Presidential Circle, Suite 430-N 4000 Hollywood Boulevard Hollywood, FL 33021 Telephone: (954) 967-6471 E-service: usz.slftl@zurichna.com Attorneys for Defendant, AJA PROPERTIES NO. 6 LTD CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing and accompanying motions has been sent via electronic mail this 11th day of August, 2021, pursuant to the Florida Rules of Civil Procedure to the following: Eric M. Tinstman, Esquire, The Tinstman Law Firm, P.A., Attorney for Plaintiffs, 2665 S. Bayshore Drive, Suite 601, Grand Bay Plaza, Miami, Florida 33133 at eric@thetinstmanlawfirm.com; Ryan M. Clancy, Esquire, Ainsworth & Clancy, Attorney for Plaintiff, 801 Brickell Ave., 9th Floor, Miami, Florida 33131 at ryan@business-esq.com; and to: Michael A. Sastre, Esquire and Aaron H. Epstein, Esquire, Sastre Saavedra & Epstein, Attorney for Blue Jay Trucking, Inc., One S.E. 3rd Avenue, Suite 1280, Miami, Florida 33131 at sastre@sselegal.com; aaron@sselegal.com and maria@sselegal.com. IMPORTANT NOTE: You must contact the other side prior to requesting a hearing so that we may assure the issue is, in fact, contested and that the appropriate amount of time is being set aside. Please contact all sides and only then submit your package.