Motion to Strike - Due Date: Complete Date:

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                          Filing # 31986264 E-Filed 09/11/2015 10:05:44 PM

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

BILLY L. BOOTH, CASE NO.: 05-1408 CA 06
Plaintiff,

v. -

TENET HEALTH SYSTEM NORTH SHORE,

INC., d/b/a NORTH SHORE MEDICAL CENTER,

a Delaware corporation, et. al.

Defendants.

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PLAINTIFF’S MOTION TO STRIKE PARAGRAPH 49 OF DEFENDANT,
NORTH SHORE MEDICAL CENTER’S EXHIBIT LIST

 

Plaintiff, BILLY BOOTH, by and through his undersigned counsel, hereby
files this his Motion to Strike Paragraph 49 of Defendant, NORTH SHORE
MEDICAL CENTER'S (“Defendant”), Exhibit List and in support thereof states:

1. On September 11, 2015, Defendant filed its Exhibit List.

2. Paragraph 49 of Defendant’s Exhibit List lists as an exhibit
“Photographs or surveillance of the Plaintiff(s).”

3. Plaintiff avers that it previously requested said exhibit from
Defendant in Paragraph 8 of its First Set of Interrogatories to Defendant filed
on March 18, 2005. Plaintiff …