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  • Linda Maldonado Plaintiff vs. NIC 4 Emerald Park Retirement Leasing LLC Defendant Neg - Nursing Home Negligence document preview
  • Linda Maldonado Plaintiff vs. NIC 4 Emerald Park Retirement Leasing LLC Defendant Neg - Nursing Home Negligence document preview
						
                                

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Filing # 45066409 E-Filed 08/10/2016 03:48:02 PM IN THE CIRCUIT COURT OF THE 17" JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: 2015-13507 (18) LINDA MALDONADO as Next Friend of BETTY STEVENS, Plaintiff, vs. NIC 4 EMERALD PARK LEASING LLC, d/b/a EMERALD PARK RETIREMENT, Defendant. / MOTION TO APPOINT ARBITRATOR Plaintiff, LINDA MALDONADO as Next Friend of BETTY STEVENS, hereby moves this Court for an order appointing an arbitrator and as grounds therefore, states: 1. 2. Plaintiff filed the complaint on the Defendant on July 30", 2015. The Defendant moved to stay the case and compel arbitration on October 22nd, 2015. The Defendant’s Motion to Compel Arbitration was granted on July 7", 2016. The Plaintiff desires to arbitrate this case in the near future. The Plaintiff does not believe that the parties will be able to agree on the independent arbitrator. The Plaintiff requests that this honorable Court select an arbitrator to act as the independent, lead arbitrator. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/10/2016 3:48:01 PM.****WHEREFORE, the Plaintiff, LINDA MALDONADOas Next Friend of BETTY STEVENS, move this honorable Court for an order granting the motion to select an arbitrator. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the fores ing was sent this 10th day of August, 2016 via electronic mail to: Scott M. Teich, Esquii P.A., Steich.pleadings@qpwblaw.com. William A. Dean, B.C.S. Florida Bar #118354 FORD, DEAN & ROTUNDO, P.A. Attorneys for Plaintiff Turnberry Plaza, Suite 600 2875 N.E. 191 Street Miami, FL 33180 Phone: (305) 670-2000 Fax: (305) 670-1353 Bill@forddean.com forddean.com (@forddean.com