Response: - TO MOTION FOR DISCOVERY SANCTIONS Due Date: Complete Date:

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                          Filing # 52485168 E-Filed 02/14/2017 03:18:00 PM

IN THE CIRCUIT COURT FOR THE ELEVENTH JUDICIAL CIRCUIT
IN AND FOR MIAMI-DADE COUNTY, FLORIDA

BRIAN ORIACH,
Plaintiff,
CASE NO. 2015-001398 CA 23

VS.

TECH CELL ENTERPRISES INC.,
And LILIAN L. LARREA

wee rss SS SD

DEFENDANTS’ REPLY TO PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION
FOR DISCOVERY SANCTIONS
COMES NOW Defendant Tech Cell Enterprises and Lillian Larrea., by and through Its
undersigned counsel and moves this court pursuant to Florida Rules of Civil Procedure 1.380(b)
and Replies to Plaintiffs response to Defendants’ motion for sanctions and moves this court to
enter sanctions against Plaintiff Brian Oriach. In support Defendant states as follows:

1 On August 17, 2016, Defendant Tech Cell Enterprises served its First Request for
Production Brian Oriach. See Exhibit “1.” The Docket of this matter identifies that the Notice
and Request for Production were filed on August 17, 2016.

2 Plaintiff Oriach has failed to respond to Pl…