On April 01, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
Nelson, Marla,
and
Greystar Management,
Harbortown Holdings, Llc,
for Neg - Negligent Security
in the District Court of Broward County.
Preview
Filing # 17310788 Electronically Filed 08/20/2014 01:47:21 PM
IN THE CIRCUIT COURT FOR THE 17th JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASE NO.: CACE- 13-009180
MARLA NELSON, individually and as Personal
Representative of the Estate of DAVID NELSON,
her husband, deceased.
Plaintiff,
Vs.
HARBOR TOWN HOLDINGS, LLC a Delaware Corporation,
and
GREP SOUTHEAST, LLC.,
a Delaware Limited Partnership
Defendants,
/
UNOPPOSED
PLAINTIFF’S MOTION FOR COMMISSION AND MANDATE
Plaintiff, MARLA NELSON, as Personal Representative of the Estate of DAVID
NELSON., through counsel, and pursuant to Fla.Stat. 92.251 (“Uniform Foreign
Depositions Law’), moves the Court for the appointment of a Commission and Mandate
in Denton County and Dallas County, Texas, and in support hereof states as follows:
Plaintiff in this wrongful death case seeks written discovery from a non-party
witness corporation residing out of state. The target of this discovery is a company
known as RealPage, based in Texas. Plaintiff seeks to issue the subpoena attached hereto
as Exhibit “A” upon RealPage, in conformity with Fla. State. 92.251 and TEX. CIV.
PRAC. & REM. §20.002.
Plaintiff has conferred with defense counsel who has no objection hereto.
WHEREFORE, the Plaintiff moves this Honorable Court for the entry of an Order
establishing a Commission and Mandate and for other such relief as is deemed
appropriate by this Court.
*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/20/2014 1:47:21 PM.****CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing was served electronically this 20th
day of August, 2014 upon William S. Reese, Esq., LANE, REESE, SUMMERS, ENNIS,
& PERDOMO, P.A., wree: ¢.com; Pete L. DeMahy, Demahy Labrador Drake
Victor Cabeza, pdemany@didlaywers.com.
»@lanere
THE HAGGARD LAW FIRM, P.A.
(Attorneys for Plaintiff)
330 Alhambra Circle, 1st Floor
Tel: 305/446-5700
Fax: 305/446-1154
By: s/Christopher Marlowe
CHRISTOPHER L. MARLOWE, ESQ.
Fla. Bar No.: 571441
elm@haggardlawfirm.com
Document Filed Date
August 20, 2014
Case Filing Date
April 01, 2013
Category
Neg - Negligent Security
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Filing # 17310788 Electronically Filed 08/20/2014 01:47:21 PM IN THE CIRCUIT COURT FOR THE 17th JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASE NO.: CACE- 13-009180 MARLA NELSON, individually and as Personal Representative of the Estate of DAVID NELSON, her husband, deceased. Plaintiff, Vs. HARBOR TOWN HOLDINGS, LLC a Delaware Corporation, and GREP SOUTHEAST, LLC., a Delaware Limited Partnership Defendants, / UNOPPOSED PLAINTIFF’S MOTION FOR COMMISSION AND MANDATE Plaintiff, MARLA NELSON, as Personal Representative of the Estate of DAVID NELSON., through counsel, and pursuant to Fla.Stat. 92.251 (“Uniform Foreign Depositions Law’), moves the Court for the appointment of a Commission and Mandate in Denton County and Dallas County, Texas, and in support hereof states as follows: Plaintiff in this wrongful death case seeks written discovery from a non-party witness corporation residing out of state. The target of this discovery is a company known as RealPage, based in Texas. Plaintiff seeks to issue the subpoena attached hereto as Exhibit “A” upon RealPage, in conformity with Fla. State. 92.251 and TEX. CIV. PRAC. & REM. §20.002. Plaintiff has conferred with defense counsel who has no objection hereto. WHEREFORE, the Plaintiff moves this Honorable Court for the entry of an Order establishing a Commission and Mandate and for other such relief as is deemed appropriate by this Court. *** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 8/20/2014 1:47:21 PM.****CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing was served electronically this 20th day of August, 2014 upon William S. Reese, Esq., LANE, REESE, SUMMERS, ENNIS, & PERDOMO, P.A., wree: ¢.com; Pete L. DeMahy, Demahy Labrador Drake Victor Cabeza, pdemany@didlaywers.com. »@lanere THE HAGGARD LAW FIRM, P.A. (Attorneys for Plaintiff) 330 Alhambra Circle, 1st Floor Tel: 305/446-5700 Fax: 305/446-1154 By: s/Christopher Marlowe CHRISTOPHER L. MARLOWE, ESQ. Fla. Bar No.: 571441 elm@haggardlawfirm.com