Motion - TO BE NOTIFIED OF ELECTIVE SURGERIESParty: Defendant Banta Properties, Inc., Defendant Colonial Park Apartments, LLC

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                          Filing # 119870538 E-Filed 01/19/2021 05:02:24 PM

IN THE CIRCUIT COURT OF THE 17TH
DISTRICT IN AND FOR BROWARD
COUNTY, FLORIDA

LUIS MORENO and MARY BEATRICE CASE NO.: CACE-20-017319
RAMOS, a married couple,

Plaintiffs,
Vv.

BANTA PROPERTIES, INC. and
COLONIAL PARK APARTMENTS, LLC,

Defendants.

DEFENDANTS’ MOTION TO BE NOTIFIED OF ELECTIVE SURGERIES

The Defendants, BANTA PROPERTIES, INC. and COLONIAL PARK
APARTMENTS, LLC (hereinafter “Defendants”), through undersigned counsel, and
pursuant to the Florida Rules of Civil Procedure, move this Honorable Court for an entry
of Order requiring the Plaintiff to notify the Defendants, at least 45 days in advance, of
any elective surgeries that the Plaintiff might undergo. In support, Defendants respectfully
state as follows:

1. This is a negligence action arising out of an incident that occurred on
November 24, 2019. The Plaintiff claims to have sustained physical injuries as a result.

1. The Plaintiff may elect, during the course of thi…