On February 03, 2023 a
Letter,Correspondence
was filed
involving a dispute between
and
for DECLARATORY - CIRCUIT
in the District Court of Pinellas County.
Preview
Filing # 189388178 E-FiIed 01/09/2024 01:19:53PM
ram uagnanu - ru box batman u 3t rewrsnurg, r1. 33 14H
gag]iano.p_aul172@gmail.com
Hon. Lorraine M. Kelly January 9, 2024
County Court Judge
County Civil Section 39
545 [st Avenue North
St. Petersburg, FL 3370i
Dear Judge Kelly,
My name is Paul Gagliano and I am the Plaintiff Pro Se in Case Number 23-943-CO currently before
this Honorable Court.
I would begin by stating it is not my intention to engage in an ex parts communication with
like t0
your Honor, and to note that the Defendants counsel has been notified of this communication both
directly and through a Court filing. While I am perhaps ignorant 0f the practice 0f law, I believe I have
a grasp 0f [he concept ofjustice.
I specifically wish to address the upcoming Motion scheduled on 1/30/2024 on your calendar to hear
Plaintifff’s Motion for Leave t0 File Amended Complaint. Defendant has been curiously silent having
been given more than ample time and resources t0 provide either an answer t0 the Motion 0r, in the
alternative, to make any attempt to conference with Plaintiff.
In keeping with Fla, R Civ. P. 1.510, Plaintiff respectfully requests that Your Honor set an ‘case
management conference’ modeled after Federal Rule 26(f). Plaintiff also requests that the time agreed
to by Plaintiff‘and Defendant to hear Plaintiff’s motion for leave to file also be used for this case
management conference to include some form of ‘Admissions’ which could guide this Honorable
Coun as t0 issues in this case for which there is a legitimate basis for dispute.
At that time, Plaintiff also respectfully requests the setting the time and place for public hearing of the
Amended Complaint and Motion for Summary Judgment.
In addition t0 the benefits to both litigants, Plaintiff also sincerely hopes that this case management
conference will assist this Honorable Court by streamlining numerous complex issues that hopefully
may be disposed of by summary judgment
Respectfully,
/s/ Paul Gagh'ano
Paul Gagliano, Plaintiff Pro Se
gagfianogaufl 72@gmai1.com
CC: Clearwater City Attorney Michael Fuino [via email at michael.fuinogcgmyclearwater.corn]
***ELECTRONICALLY FILED 01/09/2024 01:19:53 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***
Document Filed Date
January 09, 2024
Case Filing Date
February 03, 2023
Category
DECLARATORY - CIRCUIT
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 189388178 E-FiIed 01/09/2024 01:19:53PM ram uagnanu - ru box batman u 3t rewrsnurg, r1. 33 14H gag]iano.p_aul172@gmail.com Hon. Lorraine M. Kelly January 9, 2024 County Court Judge County Civil Section 39 545 [st Avenue North St. Petersburg, FL 3370i Dear Judge Kelly, My name is Paul Gagliano and I am the Plaintiff Pro Se in Case Number 23-943-CO currently before this Honorable Court. I would begin by stating it is not my intention to engage in an ex parts communication with like t0 your Honor, and to note that the Defendants counsel has been notified of this communication both directly and through a Court filing. While I am perhaps ignorant 0f the practice 0f law, I believe I have a grasp 0f [he concept ofjustice. I specifically wish to address the upcoming Motion scheduled on 1/30/2024 on your calendar to hear Plaintifff’s Motion for Leave t0 File Amended Complaint. Defendant has been curiously silent having been given more than ample time and resources t0 provide either an answer t0 the Motion 0r, in the alternative, to make any attempt to conference with Plaintiff. In keeping with Fla, R Civ. P. 1.510, Plaintiff respectfully requests that Your Honor set an ‘case management conference’ modeled after Federal Rule 26(f). Plaintiff also requests that the time agreed to by Plaintiff‘and Defendant to hear Plaintiff’s motion for leave to file also be used for this case management conference to include some form of ‘Admissions’ which could guide this Honorable Coun as t0 issues in this case for which there is a legitimate basis for dispute. At that time, Plaintiff also respectfully requests the setting the time and place for public hearing of the Amended Complaint and Motion for Summary Judgment. In addition t0 the benefits to both litigants, Plaintiff also sincerely hopes that this case management conference will assist this Honorable Court by streamlining numerous complex issues that hopefully may be disposed of by summary judgment Respectfully, /s/ Paul Gagh'ano Paul Gagliano, Plaintiff Pro Se gagfianogaufl 72@gmai1.com CC: Clearwater City Attorney Michael Fuino [via email at michael.fuinogcgmyclearwater.corn] ***ELECTRONICALLY FILED 01/09/2024 01:19:53 PM: KEN BURKE, CLERK OF THE CIRCUIT COURT, PINELLAS COUNTY***