On June 21, 2017 a
Motion,Ex Parte
was filed
involving a dispute between
Llerena, Roberto,
Llerena, Xiomara,
and
Andres Quintana Inc,
Learning And Growing Family Child Care,
Quintana Family Day Care Home,
for Comm Premises Liability
in the District Court of Miami-Dade County.
Preview
Filing # 59891451 E-Filed 08/03/2017 10:41:34 AM
IN THE CIRCUIT COURT OF THE 11TH
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA
XIOMARA LLERENA and ROBERTO GENERAL JURISDICTION DIVISION
LLERENA,
Case No: 17-014926 CA (31)
Plaintiffs,
Florida Bar No: 0084071
vs.
ANDRES QUINTANA INC, d/b/a
QUINTANA FAMILY DAY CARE
HOME a/k/a LEARNING AND
GROWING FAMILY CHILD CARE,
Defendant.
/
MOTION FOR LEAVE TO AMEND COMPLAINT BY INTERLINEATION
Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by and though
undersigned counsel, hereby moves this Honorable Court to amend their original Complaint by
Interlineation and as grounds therefore would state:
1, On or about July 11, 2017, Plaintiff herein filed a Complaint for Damages against
ANDRES QUINTANA INC. d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a
LEARNING AND GROWING FAMILY CHILD CARE.
2. Since that date, Plaintiff has discovered the correct name of ANDRES QUINTANA
INC, d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING
FAMILY CHILD .CARE to be QUINTANA FAMILY DAY CARE HOME d/b/a LEARNING
AND GROWING FAMILY CHILD CARE.
3. No prejudice shall result to any of the parties with the granting of the instant
amendment.WHEREFORE, based upon the above, Plaintiff moves this Honorable Court for the entry
of an Order permitting the amendment of their original Complaint by Interlineation to reflect the
correct legal format for the Defendant to be, QUINTANA FAMILY DAY CARB HOME d/b/a
LEARNING AND GROWING FAMILY CHILD CARE.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed
day of August, 2017 to Heather M, Calhoon, Esq., Luks, Santanicllo, Petrillo & Jones, 150
West Flagler Street, Suite 2750, Miami, Florida 33130; HCalhoon@insurancedefense.net,
FRIEDLAND LAW GROUP
1430 South Dixie Hwy., Suite 305
Coral Gables, Florida 33146
Tel: (305) 661-2008
Fax: (305) 661-2001
BY
Michael J. Carmona, Esq.
Document Filed Date
August 03, 2017
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filing # 59891451 E-Filed 08/03/2017 10:41:34 AM IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA XIOMARA LLERENA and ROBERTO GENERAL JURISDICTION DIVISION LLERENA, Case No: 17-014926 CA (31) Plaintiffs, Florida Bar No: 0084071 vs. ANDRES QUINTANA INC, d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE, Defendant. / MOTION FOR LEAVE TO AMEND COMPLAINT BY INTERLINEATION Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by and though undersigned counsel, hereby moves this Honorable Court to amend their original Complaint by Interlineation and as grounds therefore would state: 1, On or about July 11, 2017, Plaintiff herein filed a Complaint for Damages against ANDRES QUINTANA INC. d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE. 2. Since that date, Plaintiff has discovered the correct name of ANDRES QUINTANA INC, d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD .CARE to be QUINTANA FAMILY DAY CARE HOME d/b/a LEARNING AND GROWING FAMILY CHILD CARE. 3. No prejudice shall result to any of the parties with the granting of the instant amendment.WHEREFORE, based upon the above, Plaintiff moves this Honorable Court for the entry of an Order permitting the amendment of their original Complaint by Interlineation to reflect the correct legal format for the Defendant to be, QUINTANA FAMILY DAY CARB HOME d/b/a LEARNING AND GROWING FAMILY CHILD CARE. CERTIFICATE OF SERVICE THEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed day of August, 2017 to Heather M, Calhoon, Esq., Luks, Santanicllo, Petrillo & Jones, 150 West Flagler Street, Suite 2750, Miami, Florida 33130; HCalhoon@insurancedefense.net, FRIEDLAND LAW GROUP 1430 South Dixie Hwy., Suite 305 Coral Gables, Florida 33146 Tel: (305) 661-2008 Fax: (305) 661-2001 BY Michael J. Carmona, Esq.