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Filing # 25006113 E-Filed 03/18/2015 08:28:14 AM
IN THE CIRCUIT COURT OF THE 11"
JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NO. 09-36802 CA 11
WAREHOUSE 1050 CORP., ef al.,
Plaintiffs,
ve
WALTER J. WILLIAMS, ef ai.,
Defendants.
/
PLAINTIFFS’ RESPONSE IN OPPOSITION TO
COMCAST DEFENDANTS’ MOTION FOR ATTORNEY’S FEES
Plaintiffs Warehouse 1050 Corp., J and J Refrigeration Supply, Inc., and Ame
Manufacturing Corp. (collectively “Plaintiffs”), through undersigned counsel, respond to
Comcast Defendants’ Motion for Attorney’s Fees (“Motion”) as follows:
Introduction — Why Comeast’s Motion Should Be Denied!
Florida law is clear that Fla. Stat. §768.79 and Fla. R. Civ. P. 1.442, which together
govern offers of judgment, are penal in nature and must be strictly construed. Failure to comply
with any of the specific requirements of the statute and rule mandates denial of a request for
attorney’s fees and costs. As discussed further below, the Motion should be denied becaus…
