On May 07, 2019 a
Reply to Affirmative Defenses
was filed
involving a dispute between
Progressive American Ins Co,
and
Banavong, Khamla Vilaysane,
Banavong, Sithideth,
for Auto Negligence
in the District Court of Collier County.
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Filing # 94378516 E-Filed 08/19/2019 01:50:38 PM
IN THE CIRCUIT COURT IN AND FOR COLLIER COUNTY, FLORIDA.
CASE NO.: 11-2019-CA-001853-0001-XX
PROGRESSIVE AMERICAN INS. CO.
a/s/o LESLIET COLLADO ESPINOSA,
Plaintiff,
vs.
KHAMLA VILAYSANE BANAVONG,
AND SITHIDETH BANAVONG
Defendant(s).
REPLY TO AFFIRMATIVE DEFENSES
COMES NOW the Plaintiff, PROGRESSIVE AMERICAN INS. CO. a/s/o LESLIET
COLLADO ESPINOSA, by and through its undersigned attorney, and files this Reply to
Affirmative Defenses of Defendant, KHAMLA VILAYSANE BANAVONG and SITHIDETH
BANAVONG, and would state as follows:
1. The Plaintiff has reviewed the Affirmative Defenses filed by Defendant and Plaintiff
denies each and every one and further demands strict proof thereof.
I HEREBY CERTIFY that a true and correct copy of the foregoing was served on August 19,
2019 to: ALL PERSONS REGISTERED WITH THE EPORTAL SYSTEM.
MARKCITY, ROTHMAN, CANTWELL & BREITNER, P.A.
Attorneys for Plaintiff
150 S. Pine Island Road, Suite 250
Plantation, Florida 33324
Tel: (954) 474-361 6/Fax: (954) 474-0977
By: /s/ Jordan M. Breitner, Esq.
FBN: 0016411
eService@mrclawyer.com
jordan@mrclawyer.com
FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 08/19/2019 01:50:38 PM
Case Filing Date
May 07, 2019
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Filing # 94378516 E-Filed 08/19/2019 01:50:38 PM IN THE CIRCUIT COURT IN AND FOR COLLIER COUNTY, FLORIDA. CASE NO.: 11-2019-CA-001853-0001-XX PROGRESSIVE AMERICAN INS. CO. a/s/o LESLIET COLLADO ESPINOSA, Plaintiff, vs. KHAMLA VILAYSANE BANAVONG, AND SITHIDETH BANAVONG Defendant(s). REPLY TO AFFIRMATIVE DEFENSES COMES NOW the Plaintiff, PROGRESSIVE AMERICAN INS. CO. a/s/o LESLIET COLLADO ESPINOSA, by and through its undersigned attorney, and files this Reply to Affirmative Defenses of Defendant, KHAMLA VILAYSANE BANAVONG and SITHIDETH BANAVONG, and would state as follows: 1. The Plaintiff has reviewed the Affirmative Defenses filed by Defendant and Plaintiff denies each and every one and further demands strict proof thereof. I HEREBY CERTIFY that a true and correct copy of the foregoing was served on August 19, 2019 to: ALL PERSONS REGISTERED WITH THE EPORTAL SYSTEM. MARKCITY, ROTHMAN, CANTWELL & BREITNER, P.A. Attorneys for Plaintiff 150 S. Pine Island Road, Suite 250 Plantation, Florida 33324 Tel: (954) 474-361 6/Fax: (954) 474-0977 By: /s/ Jordan M. Breitner, Esq. FBN: 0016411 eService@mrclawyer.com jordan@mrclawyer.com FILED: COLLIER COUNTY, CRYSTAL K. KINZEL, CLERK, 08/19/2019 01:50:38 PM