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Filing # 102941436 E-Filed 02/07/2020 01:37:19 PM
IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN, CASE NO.: CACE-18-000390
Plaintiff,
vs.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN,
Defendants.
/
EX-PARTE MOTION FOR ORDER REVALIDATING ALL SUBPOENAS
COMES NOW, Plaintiff, NORALYS GUZMAN, by and through undersigned counsel, and
hereby files this Motion to Revalidate those trial subpoenas previously served in this matter for the
current trial period, and as grounds therefore, states as follows:
1, This case was previously set for trial, and has now has been reset to commence
February 10, 2020 through February 28, 2020.
2. Subpoenas were previously issued and served in this matter, requiring the
appearance of certain witnesses at the time of trial. See Ex. A — Trial Subpoenas.
3. In order to save resources, it is respectfully requested that this Honorable Court
revalidate those trial subpoenas by entering an order continuing the effect of those subpoenas,
issued and served on behalf of Plaintiff, for the trial February 10, 2020 through February 28, 2020.
WHEREFORE, Plaintiff, NORALYS GUZMAN, respectfully requests this Honorable
Court revalidate any and all trial subpoenas previously issued and served upon witnesses and other
parties whose presence is requested at the trial of this matter.
[Certificate of Service on following page]
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/07/2020 01:37:19 PM.****CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via
the Florida Courts E-Filing Portal to: Giselle Defalla, Esq., at Law Office of George L. Cimballa,
Ill, filgeico@geico.com, gdefalla@geico.com and jkasen@geico.com, on this oo day of
February, 2020.
KANNER & PINTALUGA, P.A.
Attorneys for Plaintiff
925 S. Federal Highway, Sixth Floor
Boca Raton, FL 33432
Phone: (561) 424-0032| Direct: (561) 892-9662
By:
FBN: 125505IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN, CASE NO.: CACE-18-000390
Plaintiff,
YB.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN,
Defendants.
/
BPOENA FOR TRIAL
THE STATE OF FLORIDA:
TO: Nighat Aziz Tahseen
c/o Giselle M. Defalla, Esq,
The Law Office of George L. Cimballs, IT
8151 Peters Rd., Ste. 1700
Plantation, FL 33324
YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL-
LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6" St., Courtroom 15175, Fort
Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June
28, 2019, to testify in this action in the above-styled case.
If you fail to appear, you may be in contempt of Court.
‘You are subpoenaed by the attomey whose name appears on this subpoena and which
subpoena is in effect up to and including the date this cause has been concluded and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.
The trial of this case can and will take place at any time in between the above-mentioned
dates, We are not certain, however, on which of the dates the trial will be held. In order to make
it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS
SUBPOENA, you may either email my office at Litt ri!Puulcyatsqikpuliomney.con oF
telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then beable to notify you of the exact time of trial and we can try to schedule a time for you to testify
that will be convenient for you. By contacting my office, this will ensure that you will be in and
out of the Courthouse as quickly and conveniently as possible.
If you are a person with disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Please contact the ADA Coordinator in the Office of the Court Administrator,
Cheryl Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale,
FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or
immediately upon receiving this notification if the time before the scheduled appearance is
less than 7 days; if you are hearing or voice impaired, call 711.
Date: _M4ay 2 1.2014
BERKIN ASLAN, ESQ.
KAN aa
Attorneys for Plaintiff
925 South Federal Highway, 6" Floor
Boca Raton, FL 33432
Phone: (561) 424-0032/Fax: (844) 818-5452
Email Designation: Picaclinys) Jakpatoriey.cam
Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN, CASE NO.: CACE-18-000390
Plaintiff,
vs.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN,
Defendants,
geen _ /
SUBPOENA FOR TRIAL
THE STATE OF FLORIDA:
TO: Ayesha Mohammed
c/o Giselle M. Defalla, Esq.
The Law Office of George L. Cimballa, HIT
8151 Peters Rd., Ste. 1700
Plantation, FL 33324
YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL-
LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6 St., Courtroom 15175, Fort
Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June
28, 2019, to testify in this action in the above-styled case.
If you fail to appear, you may be in contempt of Court.
You are subpoenaed by the attorney whose name appears on this subpoena and which
subpoena is in effect up to and including the date this cause has been concluded and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.
The trial of this case can and will take place at any time in between the above-mentioned
dates, We are not certain, however, on which of the dates the trial will be hold. In order to make
it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS
SUBPOENA, you may either email my office at | if lvinlParalcgaly@kpatlorney.com oF
telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then beable to notify you of the exact time of trial and we can try to schedule a time for you to testify
that will be convenient for you. By contacting my office, this will ensure that you will be in and
out of the Courthouse as quickly and conveniently as possible.
If you are a person with disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Please contact the ADA Coordinator in the Office of the Court Administrator,
Chery! Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale,
FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or
immediately upon receiving this notification if the time before the acheduled appearance is
less than 7 days; if you are hearing or voice impaired, call 711.
Date: Ma. 8, 2014
BERKIN ASLAN, ESQ.
Auooaya for Plaintiff
925 South Federal Highway, 6" Floor
Boca Raton, FL 33432
Phone: (561) 424-0032/Fax: (844) 818-5452
Email Designation: Picudinys! 3¢gkpnttomney.com
Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN, CASE NO.: CACE-18-000390
Plaintiff,
vs.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN,
Defendants.
i
SUBPOENA FOR TRIAL
THE STATE OF FLORIDA:
TO: Thomas Roush, MD
1818 S, Australian Ave., Ste. 108
West Palm Beach, FL 33409
YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL-
LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6" St., Courtroom 15175, Fort
Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June
28, 2019, to testify in this action in the above-styled case.
If you fail to appear, you may be in contempt of Court.
You are subpoenaed by the attorney whose name appears on this subpoena and which
subpoena is in effect up to and including the date this cause has been concluded and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.
The trial of this case can and will take place at any time in between the above-mentioned
dates, We are not certain, however, on which of the dates the trial will be held. In order to make
it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS
SUBPOENA, you may either email my office at Lit rivParulegals@kpaomey.con) OF
telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then be
able to notify you of the exact time of trial and we can try to schedule a time for you to testifythat will be convenient for you. By contacting my office, this will ensure that you will be in and
out of the Courthouse as quickly and conveniently as possible.
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost ¢o you, to the provision of certain
aasistance. Please contact the ADA Coordinator in the Office of the Court Administrator,
Cheryl Anderson, Broward County Courthouse, 201 SE 6 St., Room 880, Ft. Lauderdale,
FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or
immediately upon receiving this notification if the time before the scheduled appearance is
less than 7 days; if you are hearing or volce impaired, call 711.
BERKIN ASLAN:
For the Co:
NER & icabie PA.
Attorncys for Plaintiff
925 South Federal Highway, 6" Floor
Boca Raton, FL 33432
Phone: (561) 424-0032/Fax: (844) 818-5452
Email Designation: Pleadinys! 3agkpatorney.com
Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
NORALYS GUZMAN, CASE NO.: CACE-18-000390
Plaintiff,
vs.
AYESHA MOHAMMED, owner,
and NIGHAT AZIZ TAHSEEN,
Defendants,
!
SUBPOENA TRIAL
THE STATE OF FLORIDA:
TO: Rebecca Ramadhar
4205 NW 201" St.
Miami Gardens, FL 33055
YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL-
LISA PHILLIPS, Broward County Courthouse, 201 §.E. 6" St., Courtroom 15175, Fort
Lauderdale, FL 33301, for the jury trial commencing sometime between September 3, 2019 —
September 20, 2019, to testify in this action in the above-styled case,
If you fail to appear, you may be in contempt of Court,
You are subpoenaed by the attorney whose name appears on this subpoena and which
subpoena is in effect up to and including the date this cause has been concluded and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.
The trial of this case can and will take place at any time in between the above-mentioned
dates. We are not certain, however, on which of the dates the trial will be held. In order to make
it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS
SUBPOENA, you may either email my office at |. jal Paralegals@akps 1
telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then be
able to notify you of the exact time of trial and we can try to schedule a time for you to testifythat will be convenient for you. By contacting my office, this will ensure that you will be in and
out of the Courthouse as quickly and conveniently as possible.
If you are a person with a disability who needs any accommodation in order to
participate in this proceeding, you are entitled, at no cost to you, to the provision of certain
assistance. Please contact the ADA Coordinator in the Office of the Court Administrator,
Cheryl Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale,
FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or
immediately upon receiving this notification if the time before the scheduled appearance {s
less than 7 days; if you are hearing or voice impaired, call 711,
pate, BISI201I4
BERKIN ASLAN, ES!
For the Court
KAI & pivraiiiz PA.
Attorneys for Plaintiff
925 South Federal Highway, 6" Floor
Boca Raton, FL 33432
Phone: (561) 424-0032/Fax: (844) 818-5452
Email Designation: Ploudinys |3akpattorney.com
Florida Bar Number: 125505
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Filing # 102941436 E-Filed 02/07/2020 01:37:19 PM IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: CACE-18-000390 Plaintiff, vs. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, Defendants. / EX-PARTE MOTION FOR ORDER REVALIDATING ALL SUBPOENAS COMES NOW, Plaintiff, NORALYS GUZMAN, by and through undersigned counsel, and hereby files this Motion to Revalidate those trial subpoenas previously served in this matter for the current trial period, and as grounds therefore, states as follows: 1, This case was previously set for trial, and has now has been reset to commence February 10, 2020 through February 28, 2020. 2. Subpoenas were previously issued and served in this matter, requiring the appearance of certain witnesses at the time of trial. See Ex. A — Trial Subpoenas. 3. In order to save resources, it is respectfully requested that this Honorable Court revalidate those trial subpoenas by entering an order continuing the effect of those subpoenas, issued and served on behalf of Plaintiff, for the trial February 10, 2020 through February 28, 2020. WHEREFORE, Plaintiff, NORALYS GUZMAN, respectfully requests this Honorable Court revalidate any and all trial subpoenas previously issued and served upon witnesses and other parties whose presence is requested at the trial of this matter. [Certificate of Service on following page] *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/07/2020 01:37:19 PM.****CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been served via the Florida Courts E-Filing Portal to: Giselle Defalla, Esq., at Law Office of George L. Cimballa, Ill, filgeico@geico.com, gdefalla@geico.com and jkasen@geico.com, on this oo day of February, 2020. KANNER & PINTALUGA, P.A. Attorneys for Plaintiff 925 S. Federal Highway, Sixth Floor Boca Raton, FL 33432 Phone: (561) 424-0032| Direct: (561) 892-9662 By: FBN: 125505IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: CACE-18-000390 Plaintiff, YB. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, Defendants. / BPOENA FOR TRIAL THE STATE OF FLORIDA: TO: Nighat Aziz Tahseen c/o Giselle M. Defalla, Esq, The Law Office of George L. Cimballs, IT 8151 Peters Rd., Ste. 1700 Plantation, FL 33324 YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL- LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6" St., Courtroom 15175, Fort Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June 28, 2019, to testify in this action in the above-styled case. If you fail to appear, you may be in contempt of Court. ‘You are subpoenaed by the attomey whose name appears on this subpoena and which subpoena is in effect up to and including the date this cause has been concluded and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. The trial of this case can and will take place at any time in between the above-mentioned dates, We are not certain, however, on which of the dates the trial will be held. In order to make it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS SUBPOENA, you may either email my office at Litt ri!Puulcyatsqikpuliomney.con oF telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then beable to notify you of the exact time of trial and we can try to schedule a time for you to testify that will be convenient for you. By contacting my office, this will ensure that you will be in and out of the Courthouse as quickly and conveniently as possible. If you are a person with disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Office of the Court Administrator, Cheryl Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale, FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. Date: _M4ay 2 1.2014 BERKIN ASLAN, ESQ. KAN aa Attorneys for Plaintiff 925 South Federal Highway, 6" Floor Boca Raton, FL 33432 Phone: (561) 424-0032/Fax: (844) 818-5452 Email Designation: Picaclinys) Jakpatoriey.cam Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: CACE-18-000390 Plaintiff, vs. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, Defendants, geen _ / SUBPOENA FOR TRIAL THE STATE OF FLORIDA: TO: Ayesha Mohammed c/o Giselle M. Defalla, Esq. The Law Office of George L. Cimballa, HIT 8151 Peters Rd., Ste. 1700 Plantation, FL 33324 YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL- LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6 St., Courtroom 15175, Fort Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June 28, 2019, to testify in this action in the above-styled case. If you fail to appear, you may be in contempt of Court. You are subpoenaed by the attorney whose name appears on this subpoena and which subpoena is in effect up to and including the date this cause has been concluded and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. The trial of this case can and will take place at any time in between the above-mentioned dates, We are not certain, however, on which of the dates the trial will be hold. In order to make it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS SUBPOENA, you may either email my office at | if lvinlParalcgaly@kpatlorney.com oF telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then beable to notify you of the exact time of trial and we can try to schedule a time for you to testify that will be convenient for you. By contacting my office, this will ensure that you will be in and out of the Courthouse as quickly and conveniently as possible. If you are a person with disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Office of the Court Administrator, Chery! Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale, FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the acheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711. Date: Ma. 8, 2014 BERKIN ASLAN, ESQ. Auooaya for Plaintiff 925 South Federal Highway, 6" Floor Boca Raton, FL 33432 Phone: (561) 424-0032/Fax: (844) 818-5452 Email Designation: Picudinys! 3¢gkpnttomney.com Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: CACE-18-000390 Plaintiff, vs. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, Defendants. i SUBPOENA FOR TRIAL THE STATE OF FLORIDA: TO: Thomas Roush, MD 1818 S, Australian Ave., Ste. 108 West Palm Beach, FL 33409 YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL- LISA PHILLIPS, Broward County Courthouse, 201 S.E. 6" St., Courtroom 15175, Fort Lauderdale, FL 33301, for the jury trial commencing sometime between June 10, 2019 - June 28, 2019, to testify in this action in the above-styled case. If you fail to appear, you may be in contempt of Court. You are subpoenaed by the attorney whose name appears on this subpoena and which subpoena is in effect up to and including the date this cause has been concluded and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. The trial of this case can and will take place at any time in between the above-mentioned dates, We are not certain, however, on which of the dates the trial will be held. In order to make it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS SUBPOENA, you may either email my office at Lit rivParulegals@kpaomey.con) OF telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then be able to notify you of the exact time of trial and we can try to schedule a time for you to testifythat will be convenient for you. By contacting my office, this will ensure that you will be in and out of the Courthouse as quickly and conveniently as possible. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost ¢o you, to the provision of certain aasistance. Please contact the ADA Coordinator in the Office of the Court Administrator, Cheryl Anderson, Broward County Courthouse, 201 SE 6 St., Room 880, Ft. Lauderdale, FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or volce impaired, call 711. BERKIN ASLAN: For the Co: NER & icabie PA. Attorncys for Plaintiff 925 South Federal Highway, 6" Floor Boca Raton, FL 33432 Phone: (561) 424-0032/Fax: (844) 818-5452 Email Designation: Pleadinys! 3agkpatorney.com Florida Bar Number: 125505IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA NORALYS GUZMAN, CASE NO.: CACE-18-000390 Plaintiff, vs. AYESHA MOHAMMED, owner, and NIGHAT AZIZ TAHSEEN, Defendants, ! SUBPOENA TRIAL THE STATE OF FLORIDA: TO: Rebecca Ramadhar 4205 NW 201" St. Miami Gardens, FL 33055 YOU ARE HEREBY COMANDED to appear before the HONORABLE CAROL- LISA PHILLIPS, Broward County Courthouse, 201 §.E. 6" St., Courtroom 15175, Fort Lauderdale, FL 33301, for the jury trial commencing sometime between September 3, 2019 — September 20, 2019, to testify in this action in the above-styled case, If you fail to appear, you may be in contempt of Court, You are subpoenaed by the attorney whose name appears on this subpoena and which subpoena is in effect up to and including the date this cause has been concluded and unless excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as directed. The trial of this case can and will take place at any time in between the above-mentioned dates. We are not certain, however, on which of the dates the trial will be held. In order to make it more convenient for you, we suggest that IMMEDIATELY UPON SERVICE OF THIS SUBPOENA, you may either email my office at |. jal Paralegals@akps 1 telephone my office at 561-892-9894 and ask to speak to either me or Rose Smith. I will then be able to notify you of the exact time of trial and we can try to schedule a time for you to testifythat will be convenient for you. By contacting my office, this will ensure that you will be in and out of the Courthouse as quickly and conveniently as possible. If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact the ADA Coordinator in the Office of the Court Administrator, Cheryl Anderson, Broward County Courthouse, 201 SE 6" St., Room 880, Ft. Lauderdale, FL 33301, (954) 831-7721 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance {s less than 7 days; if you are hearing or voice impaired, call 711, pate, BISI201I4 BERKIN ASLAN, ES! For the Court KAI & pivraiiiz PA. Attorneys for Plaintiff 925 South Federal Highway, 6" Floor Boca Raton, FL 33432 Phone: (561) 424-0032/Fax: (844) 818-5452 Email Designation: Ploudinys |3akpattorney.com Florida Bar Number: 125505