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  • CARTWRIGHT, NORMAN L III vs R T BROWN INCOTHER NEGLIGENCE document preview
  • CARTWRIGHT, NORMAN L III vs R T BROWN INCOTHER NEGLIGENCE document preview
						
                                

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Filing # 132869195 E-Filed 08/17/2021 04:32:28 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR CITRUS COUNTY, FLORIDA NORMAN L. CARTWRIGHT, III CASE NO.: 2021 CA 000537 A and COLLEEN CARTWRIGHT, Plaintiffs, vs. R. T. BROWN, INC., d/b/a BROWN FUNERAL HOME AND CREMATORY, and CITRUS MEMORIAL HOSPITAL, INC., Defendants. / PLAINTIFF’S RESPONSE TO DEFENDANT, CITRUS MEMORIAL HOSPITAL, INC.’S AFFIRMATIVE DEFENSES Plaintiff, NORMAN L. CARTWRIGHT, Ill, by and through the undersigned attorney hereby files this Response to Affirmative Defenses filed by Defendant, CITRUS MEMORIAL HOSPITAL, INC., on or about August 11, 2021, and states as follows: Plaintiff, NORMAN L. CARTWRIGHT, Ill, denies each and every affirmative defense raised by Defendant, CITRUS MEMORIAL HOSPITAL, INC., and demands strict proof thereof. CERTIFICATE OF SERVICE | HEREBY CERTIFY that on this 17 Gay of August, 2021, the undersigned has electronically filed the foregoing with the Citrus County Clerk of the Court by using the e-Filing Portal and that a true and correct copy of the foregoing has been furnished to: Joseph Kinman, Jr., Esquire, Beytin, McLaughlin, McLaughlin, O'Hara, Kinman & Bocchino, 1706 E Eleventh Ave, Tampa, FL 33605 at the following designated E-Mail: jfk@\aw-fla.com; jlb@law-fla.com. S D. HIPPELHEUSER, ESQUIRE rida Bar No.: 0784559 tom@pbcmillerlaw.com LAW OFFICES OF BRENT C. MILLER, P.A. 205 East Burleigh Boulevard Tavares, FL 32778 (352) 343-7400 Fax: (352) 343-9152 litigation: illerlaw.com Attorney for Plaintiff