On March 18, 2005 a
Motion,Ex Parte
was filed
involving a dispute between
Horrell, Kevin,
and
Klein, William R,
W R Klein Pa,
for OTHER NEGLIGENCY - CIRCUIT
in the District Court of Sarasota County.
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT
INAND FOR SARASOTA COUNTY, FLORIDA
KEVIN HORRELL,
Plaintiff,
VS.
Case No. 2005 CA 2705 Ne
WILLIAM R. KLEIN and
W.R. KLEIN, P.A.
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MOTION TO DISMISS FOR PRIOR PENDING ACTION
COMES NOW Defendant, WILLIAM R. KLEIN, by and through his undersigned
counsel, in complaint of the Summons and Complaint filed herein under Case No.
2005CA2705 NC, and states that the Defendant WILLIAM R. KLEIN is in fact a
Defendant in a case alleging certain specific facts identical to the ones contained in the
above Complaint in Case No. 2001CA10315NC.
1.
The Defendant moves to dismiss the Summons and Complaint in the
within action against Defendant William R. Klein, as all the issues of this action are
contained in the above mentioned suit under the 2001 Docket.
2.
William R. Klein would also consent to an order amending the Caption and
Complaint in 2001CA1031 5NC so that W.R. Klein, P.A. , may be added thereto, so that
all issues may be tried jointly without the appearance of Plaintiff Judge Shopping.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via U.S. Mail, postage prepaid to William H. Phelan, Jr., Bond, Arnett, Phelan,
+
’Smith & Craggs, P.A.., P.O. Box 2405, Ocala, Florida 34478 this (4 day of July 2005.
LEIN, P.A.
Calvih J. Domenico, Jr., Esquire
FBN 713080
1900 Main Street, Suite 310
Sarasota, FL 34236 ©
Telephone (941) 365-1930
Facsimile (941) 953-3685
_ Attorneys for Defendant ~~
Document Filed Date
July 18, 2005
Case Filing Date
March 18, 2005
Category
OTHER NEGLIGENCY - CIRCUIT
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