Motion to Strike - Due Date: Complete Date:

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                          Filing # 19510859 Electronically Filed 10/17/2014 11:36:55 AM

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL
CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO. 13 - 18039 CA 01
SOUTH DADE LANDSCAPING, INC.;
and JOBRIZ BUILDERS
CORPORATION

Plaintiff DEFENDANTS’ MOTION TO
v. STRIKE

ESTEBAN L. SUAREZ; et al

Defendants

The Defendants, Esteban Suarez, Jean Duret and Alfredo Brizuela, by undersigned
counsel, move the court for an order striking the plaintiffs trial exhibits. For grounds, the
defendants will show the court that the plaintiffs have failed to provide their trial exhibits
to the defendants so that they could be deposed. The latest failure occurred on October 9”
and 10", 2014, when plaintiffs appeared for deposition duces tecum but failed to bring their
trial exhibits.

WHEREFORE, it is prayed that this motion be granted. In the alternative,
Defendants pray for an order requiring plaintiffs to again appear for depositions with the
trial exhibits and sanctions.

Joseph J…