On July 30, 2015 a
Motion-Secondary
was filed
involving a dispute between
Mombranche, Mikey,
and
Aslin, Chad,
Hernandez, Daniela,
Ims Landscaping, Inc,
for Auto Negligence
in the District Court of Broward County.
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Filing # 60101270 E-Filed 08/08/2017 12:04:38 PM
IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
MIKEY MOMBRANCHE CASE NO.: CACE 15-13571
Plaintiff,
vs.
DANIELA HERNANDEZ, CHAD ASLIN
and IMS LANDSCAPING, INC.
Defendants.
PLAINTIFF’S REPLY TO DEFENDANTS, DANIELA HERNANDEZ AND IMS
LANDSCAPING, INC’S_ AFFIRMATIVE DEFENSES
COMES NOW, the Plaintiff, MIKEY MOMBRANCHE, by and through
undersigned attorneys, and denies each and every affirmative defense of the Defendants,
DANIELA HERNANDEZ and IMS LANDSCAPING, INC’S Affirmative Defenses to
Plaintiff's Complaint, and seeks to avoid same and demands strict proof thereof.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that true and correct copies of the foregoing was furnished
by eservice to Attorney for Defendants, Michael Davies, Esq., Nicholas J. Ryan &
Associates, Attorneys for Defendants, 110 S.E. 6" Street, Suite 2100, fort Lauderdale, FL
33301 on the 8" day of August, 2017.
REINFELD | CABRERA | TISON
10235 W. Sample Road, Suite 207
Coral Springs, FL 33065
Telephone: 954-334-1520
Facsimile: 954-334-1526
/S/ Devin P. Tison
Devin P. Tison, Esq.
Florida Bar No. 95225
service@myflattorney.com
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 8/8/2017 12:04:38 PM.****
Preview
Filing # 60101270 E-Filed 08/08/2017 12:04:38 PM IN THE CIRCUIT COURT OF THE 17™ JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MIKEY MOMBRANCHE CASE NO.: CACE 15-13571 Plaintiff, vs. DANIELA HERNANDEZ, CHAD ASLIN and IMS LANDSCAPING, INC. Defendants. PLAINTIFF’S REPLY TO DEFENDANTS, DANIELA HERNANDEZ AND IMS LANDSCAPING, INC’S_ AFFIRMATIVE DEFENSES COMES NOW, the Plaintiff, MIKEY MOMBRANCHE, by and through undersigned attorneys, and denies each and every affirmative defense of the Defendants, DANIELA HERNANDEZ and IMS LANDSCAPING, INC’S Affirmative Defenses to Plaintiff's Complaint, and seeks to avoid same and demands strict proof thereof. CERTIFICATE OF SERVICE I HEREBY CERTIFY that true and correct copies of the foregoing was furnished by eservice to Attorney for Defendants, Michael Davies, Esq., Nicholas J. Ryan & Associates, Attorneys for Defendants, 110 S.E. 6" Street, Suite 2100, fort Lauderdale, FL 33301 on the 8" day of August, 2017. REINFELD | CABRERA | TISON 10235 W. Sample Road, Suite 207 Coral Springs, FL 33065 Telephone: 954-334-1520 Facsimile: 954-334-1526 /S/ Devin P. Tison Devin P. Tison, Esq. Florida Bar No. 95225 service@myflattorney.com *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 8/8/2017 12:04:38 PM.****