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Filing # 196400725 E-Filed 04/17/2024 01:58:00 PM
FORM 1.997. CIVIL COVER SHEET
The civil cover sheet and the information contained in it neither replace nor supplement the filing
and service of pleadings or other documents as required by law. This form must be filed by the
plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant
to section 25.075, Florida Statutes. (See instructions for completion.)
1 CASE STYLE
IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT
IN AND FOR ALACHUA COUNTY, FLORIDA
(Name of Court).
Plaintiff JOHN GORDON Case #
Judge
vs.
Defendants_EXACTECH, INC.; EXACTECH U.S.,
INC.; WILLIAM PETTY; BETTY PETTY; ETAL.
I. AMOUNT OF CLAIM
Please indicate the estimated amount of the claim, rounded to the nearest dollar. $
OVER $100,000.00
Til. TYPE OF CASE (If the case fits more than one type of case, select the most
definitive category.) If the most descriptive label is a subcategory (is indented under a
broader category), place an x on both the main category and subcategory lines.
CIRCUIT CIVIL
Condominium
Contracts and indebtedness
Eminent domain
Auto negligence
Negligence—other
Business governance
Business torts
Environmental/Toxic tort
Third party indemnification
Construction defect
Mass tort
Negligent security
Nursing home negligence
Premises liability—commercial
Premises liability—tresidential
x Products liability
Real property/Mortgage foreclosure
"2024 CA 001316" 196400725 Filed at Alachua County Clerk 04/17/2024 01:58:08 PM EDT
Commercial foreclosure
__ Homestead residential foreclosure
Non-homestead residential foreclosure
__ Other real property actions
Professional malpractice
Malpractice—business
Malpractice—medical
Malpractice—other professional
Other
Antitrust/Trade regulation
Business transactions
Constitutional challenge—statute or ordinance
Constitutional challenge—proposed amendment
Corporate trusts
Discrimination—employment or other
Insurance claims
Intellectual property
Libel/Slander
Shareholder derivative action
Securities litigation
Trade secrets
Trust litigation
COUNTY CIVIL
>x Civil
Replevins
Evictions
Other civil (non-monetary)
Iv. REMEDIES SOUGHT (check all that apply):
+1x Monetary;
Nonmonetary declaratory or injunctive relief; Punitive
——
Vv. NUMBER OF CAUSES OF ACTION: [ 10 ]
(Specify) Negligence; Strict Liability - Manufacturing Defect, Design Defect, Failure To Warn; Breach of Post-Market
Duty to Warn; Negligent Misrepresentation; Breach of Express Warranty; Breach of Implied Warranty; Information Negligently
Supplied for the Guidance of Other; Consumer Protection Act.
VI. IS THIS CASE A CLASS ACTION LAWSUIT?
yes
x no
VI. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED?
x no
yes If “yes,” list all related cases by name, case number, and court.
VII. IS JURY TRIAL DEMANDED IN COMPLAINT?
xX yes
——_ no
I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my
knowledge and belief, and that I have read and will comply with the requirements of Florida
Rule of Judicial Administration 2.425.
Signature /s/ llyas Sayeg Fla. Bar# _99140
Attorney or party (Bar # if attorney)
llyas Sayeg, Esq. 04/17/2024
(type or print name) Date
FORM 1.997. INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL
COVER SHEET
Plaintiff must file this cover sheet with the first document filed in the action or proceeding
(except small claims cases, probate, or family cases). Domestic and juvenile cases should be
accompanied by a completed Florida Family Law Rules of Procedure Form 12.928, Cover Sheet
for Family Court Cases. Failure to file a civil cover sheet in any civil case other than those
excepted above may result in sanctions.
I. Case Style. Enter the name of the court, the appropriate case number assigned at the time
of filing of the original complaint or petition, the name of the judge assigned (if applicable), and
the name (last, first, middle initial) of plaintiff(s) and defendant(s).
Il. Amount of Claim. Enter the estimated amount of the claim, rounded to the nearest
dollar. The estimated amount of the claim is requested for data collection and clerical processing
purposes and is not considered dispositive of the claim.
iil. Type of Case. Place an “X” on the appropriate line. If the cause fits more than one type
of case, select the most definitive. If the most definitive label is a subcategory (indented under a
broader category label), place an “X” on the category and subcategory lines. Definitions of the
cases are provided below in the order they appear on the form.
Circuit Civil
(A) Condominium—all civil lawsuits pursuant to Chapter 718, Florida Statutes, in
which a condominium association is a party.
(8) Contracts and indebtedness—all contract actions relating to promissory notes and
other debts, including those arising from the sale of goods, but excluding contract disputes
involving condominium associations.
©) Eminent domain—all matters relating to the taking of private property for public
use, including inverse condemnation by state agencies, political subdivisions, or public service
corporations.
0) Auto negligence—all matters arising out of a party’s allegedly negligent operation
of a motor vehicle.
©) Negligence—other—all actions sounding in negligence, including statutory
claims for relief on account of death or injury, that are not included in other main categories.
®) Business governance—all matters relating to the management, administration, or
control of a company.
G) Business torts—all matters relating to liability for economic loss allegedly caused
by interference with economic or business relationships.
(A) Environmental/Toxic tort—all matters relating to claims that violations of
environmental regulatory provisions or exposure to a chemical caused injury or disease.
@ Third party indemnification—all matters relating to liability transferred to a third
party in a financial relationship.
) Construction defect—all civil lawsuits in which damage or injury was allegedly
caused by defects in the construction of a structure.
(K) Mass tort—all matters relating to a civil action involving numerous plaintiffs
against one or more defendants.
@) Negligent security—all matters involving injury to a person or property allegedly
resulting from insufficient security.
(™) Nursing home negligence—all matters involving injury to a nursing home
resident resulting from negligence of nursing home staff or facilities.
) Premises liability—commercial—all matters involving injury to a person or
property allegedly resulting from a defect on the premises of a commercial property.
(0) Premises liability—residential—all matters involving injury to a person or
property allegedly resulting from a defect on the premises of a residential property.
() Products liability—all matters involving injury to a person or property allegedly
resulting from the manufacture or sale of a defective product or from a failure to warn.
Q Real property/Mortgage foreclosure—all matters relating to the possession, title,
or boundaries of real property. All matters involving foreclosures or sales of real property,
including foreclosures associated with condominium associations or condominium units. (The
amount of claim specified in Section II. of the form determines the filing fee pursuant to section
28.241, Florida Statutes.)
Q®) Commercial foreclosure—all matters relating to the termination of a business
owner’s interest in commercial property by a lender to gain title or force a sale to satisfy the
unpaid debt secured by the property.
(S) Homestead residential foreclosure—all matters relating to the termination of a
residential property owner’s interest by a lender to gain title or force a sale to satisfy the unpaid
debt secured by the property where the property has been granted a homestead exemption.
(1) Nonhomestead residential foreclosure—all matters relating to the termination of a
residential property owner’s interest by a lender to gain title or force a sale to satisfy the unpaid
debt secured by the property where the property has not been granted a homestead exemption.
(WU) Other real property actions—all matters relating to land, land improvements, or
property rights not involving commercial or residential foreclosure.
vy) Professional malpractice—all professional malpractice lawsuits.
(W) Malpractice—business—all matters relating to a business’s or business person’s
failure to exercise the degree of care and skill that someone in the same line of work would use
under similar circumstances.
& Malpractice—medical—all matters relating to a doctor’s failure to exercise the
degree of care and skill that a physician or surgeon of the same medical specialty would use
under similar circumstances.
YY) Malpractice—other professional—all matters relating to negligence of those other
than medical or business professionals.
(2) Other—all civil matters not included in other categories.
(AA) Antitrust/Trade regulation—all matters relating to unfair methods of competition
or unfair or deceptive business acts or practices.
(AB) Business transactions—all matters relating to actions that affect financial or
economic interests.
(AC) Constitutional challenge—statute or ordinance—a challenge to a statute or
ordinance, citing a violation of the Florida Constitution.
(AD) Constitutional challenge—proposed amendment—a challenge to a legislatively
initiated proposed constitutional amendment, but excluding challenges to a citizen-initiated
proposed constitutional amendment because the Florida Supreme Court has direct jurisdiction of
such challenges.
(AE) Corporate trusts—all matters relating to the business activities of financial
services companies or banks acting in a fiduciary capacity for investors.
(AF) _ Discrimination—employment or other—all matters relating to discrimination,
including employment, sex, race, age, handicap, harassment, retaliation, or wages.
(AG) Insurance claims—all matters relating to claims filed with an insurance company.
(AH) Intellectual property—all matters relating to intangible rights protecting
commercially valuable products of the human intellect.
(AD Libel/Slander—all matters relating to written, visual, oral, or aural defamation of
character.
(AJ) Shareholder derivative action—all matters relating to actions by a corporation’s
shareholders to protect and benefit all shareholders against corporate management for improper
management.
(AK) Securities litigation—all matters relating to the financial interest or instruments of
a company or corporation.
(AL) _ Trade secrets—all matters relating to a formula, process, device, or other business
information that is kept confidential to maintain an advantage over competitors.
(AM) Trust litigation—all civil matters involving guardianships, estates, or trusts and
not appropriately filed in probate proceedings.
County Civil
(AN) Civil — all matters involving claims ranging from $8,001 through $30,000 in
damages, exclusive of interest, costs, and attomey fees.
(AO) Replevins—all lawsuits pursuant to Chapter 78, Florida Statutes, involving claims
up to $30,000.
(AP) Evictions—all matters involving the recovery of possession of leased land or
rental property by process of law.
(AQ) Other civil (non-monetary)— includes all other non-monetary county civil matters
that were not described in other county civil categories.
IV. Remedies Sought. Place an “X” on the appropriate line. If more than one remedy is
sought in the complaint or petition, check all that apply.
Vv. Number of Causes of Action. If the complaint or petition alleges more than one cause of
action, note the number and the name of the cause of action.
VI. Class Action. Place an “X” on the appropriate line.
VI. Related Cases. Place an “X” on the appropriate line.
VIII. Is Jury Trial Demanded In Complaint? Check the appropriate line to indicate whether
a jury trial is being demanded in the complaint.
ATTORNEY OR PARTY SIGNATURE. Sign the civil cover sheet. Print legibly the name of
the person signing the civil cover sheet. Attomeys must include a Florida Bar number. Insert
the date the civil cover sheet is signed. Signature is a certification that the filer has provided
accurate information on the civil cover sheet, and has read and complied with the
requirements of Florida Rule of Judicial Administration 2.425,
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Filing # 196400725 E-Filed 04/17/2024 01:58:00 PM FORM 1.997. CIVIL COVER SHEET The civil cover sheet and the information contained in it neither replace nor supplement the filing and service of pleadings or other documents as required by law. This form must be filed by the plaintiff or petitioner with the Clerk of Court for the purpose of reporting uniform data pursuant to section 25.075, Florida Statutes. (See instructions for completion.) 1 CASE STYLE IN THE CIRCUIT COURT OF THE EIGHTH JUDICIAL CIRCUIT IN AND FOR ALACHUA COUNTY, FLORIDA (Name of Court). Plaintiff JOHN GORDON Case # Judge vs. Defendants_EXACTECH, INC.; EXACTECH U.S., INC.; WILLIAM PETTY; BETTY PETTY; ETAL. I. AMOUNT OF CLAIM Please indicate the estimated amount of the claim, rounded to the nearest dollar. $ OVER $100,000.00 Til. TYPE OF CASE (If the case fits more than one type of case, select the most definitive category.) If the most descriptive label is a subcategory (is indented under a broader category), place an x on both the main category and subcategory lines. CIRCUIT CIVIL Condominium Contracts and indebtedness Eminent domain Auto negligence Negligence—other Business governance Business torts Environmental/Toxic tort Third party indemnification Construction defect Mass tort Negligent security Nursing home negligence Premises liability—commercial Premises liability—tresidential x Products liability Real property/Mortgage foreclosure "2024 CA 001316" 196400725 Filed at Alachua County Clerk 04/17/2024 01:58:08 PM EDT Commercial foreclosure __ Homestead residential foreclosure Non-homestead residential foreclosure __ Other real property actions Professional malpractice Malpractice—business Malpractice—medical Malpractice—other professional Other Antitrust/Trade regulation Business transactions Constitutional challenge—statute or ordinance Constitutional challenge—proposed amendment Corporate trusts Discrimination—employment or other Insurance claims Intellectual property Libel/Slander Shareholder derivative action Securities litigation Trade secrets Trust litigation COUNTY CIVIL >x Civil Replevins Evictions Other civil (non-monetary) Iv. REMEDIES SOUGHT (check all that apply): +1x Monetary; Nonmonetary declaratory or injunctive relief; Punitive —— Vv. NUMBER OF CAUSES OF ACTION: [ 10 ] (Specify) Negligence; Strict Liability - Manufacturing Defect, Design Defect, Failure To Warn; Breach of Post-Market Duty to Warn; Negligent Misrepresentation; Breach of Express Warranty; Breach of Implied Warranty; Information Negligently Supplied for the Guidance of Other; Consumer Protection Act. VI. IS THIS CASE A CLASS ACTION LAWSUIT? yes x no VI. HAS NOTICE OF ANY KNOWN RELATED CASE BEEN FILED? x no yes If “yes,” list all related cases by name, case number, and court. VII. IS JURY TRIAL DEMANDED IN COMPLAINT? xX yes ——_ no I CERTIFY that the information I have provided in this cover sheet is accurate to the best of my knowledge and belief, and that I have read and will comply with the requirements of Florida Rule of Judicial Administration 2.425. Signature /s/ llyas Sayeg Fla. Bar# _99140 Attorney or party (Bar # if attorney) llyas Sayeg, Esq. 04/17/2024 (type or print name) Date FORM 1.997. INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET Plaintiff must file this cover sheet with the first document filed in the action or proceeding (except small claims cases, probate, or family cases). Domestic and juvenile cases should be accompanied by a completed Florida Family Law Rules of Procedure Form 12.928, Cover Sheet for Family Court Cases. Failure to file a civil cover sheet in any civil case other than those excepted above may result in sanctions. I. Case Style. Enter the name of the court, the appropriate case number assigned at the time of filing of the original complaint or petition, the name of the judge assigned (if applicable), and the name (last, first, middle initial) of plaintiff(s) and defendant(s). Il. Amount of Claim. Enter the estimated amount of the claim, rounded to the nearest dollar. The estimated amount of the claim is requested for data collection and clerical processing purposes and is not considered dispositive of the claim. iil. Type of Case. Place an “X” on the appropriate line. If the cause fits more than one type of case, select the most definitive. If the most definitive label is a subcategory (indented under a broader category label), place an “X” on the category and subcategory lines. Definitions of the cases are provided below in the order they appear on the form. Circuit Civil (A) Condominium—all civil lawsuits pursuant to Chapter 718, Florida Statutes, in which a condominium association is a party. (8) Contracts and indebtedness—all contract actions relating to promissory notes and other debts, including those arising from the sale of goods, but excluding contract disputes involving condominium associations. ©) Eminent domain—all matters relating to the taking of private property for public use, including inverse condemnation by state agencies, political subdivisions, or public service corporations. 0) Auto negligence—all matters arising out of a party’s allegedly negligent operation of a motor vehicle. ©) Negligence—other—all actions sounding in negligence, including statutory claims for relief on account of death or injury, that are not included in other main categories. ®) Business governance—all matters relating to the management, administration, or control of a company. G) Business torts—all matters relating to liability for economic loss allegedly caused by interference with economic or business relationships. (A) Environmental/Toxic tort—all matters relating to claims that violations of environmental regulatory provisions or exposure to a chemical caused injury or disease. @ Third party indemnification—all matters relating to liability transferred to a third party in a financial relationship. ) Construction defect—all civil lawsuits in which damage or injury was allegedly caused by defects in the construction of a structure. (K) Mass tort—all matters relating to a civil action involving numerous plaintiffs against one or more defendants. @) Negligent security—all matters involving injury to a person or property allegedly resulting from insufficient security. (™) Nursing home negligence—all matters involving injury to a nursing home resident resulting from negligence of nursing home staff or facilities. ) Premises liability—commercial—all matters involving injury to a person or property allegedly resulting from a defect on the premises of a commercial property. (0) Premises liability—residential—all matters involving injury to a person or property allegedly resulting from a defect on the premises of a residential property. () Products liability—all matters involving injury to a person or property allegedly resulting from the manufacture or sale of a defective product or from a failure to warn. Q Real property/Mortgage foreclosure—all matters relating to the possession, title, or boundaries of real property. All matters involving foreclosures or sales of real property, including foreclosures associated with condominium associations or condominium units. (The amount of claim specified in Section II. of the form determines the filing fee pursuant to section 28.241, Florida Statutes.) Q®) Commercial foreclosure—all matters relating to the termination of a business owner’s interest in commercial property by a lender to gain title or force a sale to satisfy the unpaid debt secured by the property. (S) Homestead residential foreclosure—all matters relating to the termination of a residential property owner’s interest by a lender to gain title or force a sale to satisfy the unpaid debt secured by the property where the property has been granted a homestead exemption. (1) Nonhomestead residential foreclosure—all matters relating to the termination of a residential property owner’s interest by a lender to gain title or force a sale to satisfy the unpaid debt secured by the property where the property has not been granted a homestead exemption. (WU) Other real property actions—all matters relating to land, land improvements, or property rights not involving commercial or residential foreclosure. vy) Professional malpractice—all professional malpractice lawsuits. (W) Malpractice—business—all matters relating to a business’s or business person’s failure to exercise the degree of care and skill that someone in the same line of work would use under similar circumstances. & Malpractice—medical—all matters relating to a doctor’s failure to exercise the degree of care and skill that a physician or surgeon of the same medical specialty would use under similar circumstances. YY) Malpractice—other professional—all matters relating to negligence of those other than medical or business professionals. (2) Other—all civil matters not included in other categories. (AA) Antitrust/Trade regulation—all matters relating to unfair methods of competition or unfair or deceptive business acts or practices. (AB) Business transactions—all matters relating to actions that affect financial or economic interests. (AC) Constitutional challenge—statute or ordinance—a challenge to a statute or ordinance, citing a violation of the Florida Constitution. (AD) Constitutional challenge—proposed amendment—a challenge to a legislatively initiated proposed constitutional amendment, but excluding challenges to a citizen-initiated proposed constitutional amendment because the Florida Supreme Court has direct jurisdiction of such challenges. (AE) Corporate trusts—all matters relating to the business activities of financial services companies or banks acting in a fiduciary capacity for investors. (AF) _ Discrimination—employment or other—all matters relating to discrimination, including employment, sex, race, age, handicap, harassment, retaliation, or wages. (AG) Insurance claims—all matters relating to claims filed with an insurance company. (AH) Intellectual property—all matters relating to intangible rights protecting commercially valuable products of the human intellect. (AD Libel/Slander—all matters relating to written, visual, oral, or aural defamation of character. (AJ) Shareholder derivative action—all matters relating to actions by a corporation’s shareholders to protect and benefit all shareholders against corporate management for improper management. (AK) Securities litigation—all matters relating to the financial interest or instruments of a company or corporation. (AL) _ Trade secrets—all matters relating to a formula, process, device, or other business information that is kept confidential to maintain an advantage over competitors. (AM) Trust litigation—all civil matters involving guardianships, estates, or trusts and not appropriately filed in probate proceedings. County Civil (AN) Civil — all matters involving claims ranging from $8,001 through $30,000 in damages, exclusive of interest, costs, and attomey fees. (AO) Replevins—all lawsuits pursuant to Chapter 78, Florida Statutes, involving claims up to $30,000. (AP) Evictions—all matters involving the recovery of possession of leased land or rental property by process of law. (AQ) Other civil (non-monetary)— includes all other non-monetary county civil matters that were not described in other county civil categories. IV. Remedies Sought. Place an “X” on the appropriate line. If more than one remedy is sought in the complaint or petition, check all that apply. Vv. Number of Causes of Action. If the complaint or petition alleges more than one cause of action, note the number and the name of the cause of action. VI. Class Action. Place an “X” on the appropriate line. VI. Related Cases. Place an “X” on the appropriate line. VIII. Is Jury Trial Demanded In Complaint? Check the appropriate line to indicate whether a jury trial is being demanded in the complaint. ATTORNEY OR PARTY SIGNATURE. Sign the civil cover sheet. Print legibly the name of the person signing the civil cover sheet. Attomeys must include a Florida Bar number. Insert the date the civil cover sheet is signed. Signature is a certification that the filer has provided accurate information on the civil cover sheet, and has read and complied with the requirements of Florida Rule of Judicial Administration 2.425,