On May 10, 101 a
was filed
involving a dispute between
Beaugrand, Iris,
and
O'Toole, Robert,
for Other - Matters not falling within the Other Civil Subcategories
in the District Court of Charlotte County.
Preview
Filing # 90491355 E-Filed 06/03/2019 05:44:53 PM
IN THE 20™ CIRCUIT COURT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CASE #2017 CA 000181
IRIS BEAUGRAND, etc.,
Plaintiff! Counter-Defendant,
v, REPLY OF BOB O’TOOLE TO
ANSWER FILED BY BEAUGRAND
ROBERT O’TOOLE,
Defendant/Counter-Plaintify.
As provided in Fla.R.Civ.Pro. 1.100(a), Counter-Plaintiff ROBERT O’TOOLE replies to
the Answer & Affirmative Defenses submitted in this case by Counter-Defendant IRIS
BEAUGRAND by denying the same and demanding strict proof thereof. Specifically, he denies
that the claims he has brought in this case were adjudicated in the referenced companion case in
Sarasota County Circuit Court or are otherwise the subject of res judicata, collateral estoppel or
other defenses Beaugrand has attempted, or attempts to assert in this action to avoid being held
accountable in this case, nor was O’Toole given a fair opportunity to be heard in that case.
J DO HEREBY CERTIFY that a true and correct copy of the foregoing was caused to
be served by electronic mail on June 3, 2019, upon Steele T. Williams, Esquire, STEELE T
WILLIAMS, PA, attorney for plaintiff, Pineapple Place, 1381 McAnsh Square, Sarasota, Florida,
34236; Steele TWilliams@Comceast,Net.
Respectfully submitted,
BRET SHAWN CLARK, PA
PO BOX 1133
Englewood, Florida 34295
Tel: (941) 404-4704
BretClark@WebNetLawyer.Com
(Bret Clank
Bret Clark, Esquire FB #384038
Attorney for Defendant/Counter-Plaintiff
Robert O’ Toole
Document Filed Date
November 01, 2023
Case Filing Date
May 10, 101
Category
Other - Matters not falling within the Other Civil Subcategories
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Filing # 90491355 E-Filed 06/03/2019 05:44:53 PM IN THE 20™ CIRCUIT COURT IN AND FOR CHARLOTTE COUNTY, FLORIDA CASE #2017 CA 000181 IRIS BEAUGRAND, etc., Plaintiff! Counter-Defendant, v, REPLY OF BOB O’TOOLE TO ANSWER FILED BY BEAUGRAND ROBERT O’TOOLE, Defendant/Counter-Plaintify. As provided in Fla.R.Civ.Pro. 1.100(a), Counter-Plaintiff ROBERT O’TOOLE replies to the Answer & Affirmative Defenses submitted in this case by Counter-Defendant IRIS BEAUGRAND by denying the same and demanding strict proof thereof. Specifically, he denies that the claims he has brought in this case were adjudicated in the referenced companion case in Sarasota County Circuit Court or are otherwise the subject of res judicata, collateral estoppel or other defenses Beaugrand has attempted, or attempts to assert in this action to avoid being held accountable in this case, nor was O’Toole given a fair opportunity to be heard in that case. J DO HEREBY CERTIFY that a true and correct copy of the foregoing was caused to be served by electronic mail on June 3, 2019, upon Steele T. Williams, Esquire, STEELE T WILLIAMS, PA, attorney for plaintiff, Pineapple Place, 1381 McAnsh Square, Sarasota, Florida, 34236; Steele TWilliams@Comceast,Net. Respectfully submitted, BRET SHAWN CLARK, PA PO BOX 1133 Englewood, Florida 34295 Tel: (941) 404-4704 BretClark@WebNetLawyer.Com (Bret Clank Bret Clark, Esquire FB #384038 Attorney for Defendant/Counter-Plaintiff Robert O’ Toole