On December 21, 2018 a Motion,Ex Parte was filed involving a dispute between Valdes, Rosa H, and Anderson, Greg, Becton, Danny, Bowman, Aaron, Boyer, Lori N, City Of Tampa Bob Buckhorn, Crescumbeni, John R, Duval County City Council, Ferraro, Al, Freeman, Terrance, Gaffney, Reggie, Garrett, Dennis L, Gulliford, Bill, Hagan, Ken, Hazouri, Tommy, Hillsborough County Commissioners, Kemp, Pat, Lopez Brosche, Anna, Miller, Lesley, Morgan, Joyce, Murman, Sandra, Newby, Samuel, Overman, Kimberly, Pittman, Ju'Coby, Smith, Mariella, State Of Florida, White, Randy, White, Stacy, Wilson, Scott, for Civil in the District Court of Hillsborough County.
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Filing #83003988 E-Filed 01/08/2019 12:04:21 PM IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT OF THE STATE OF FLORIDA, IN AND FOR HILLSBOROUGH COUNTY CIVIL DIVISION ROSA H. VALDES Appellants, CASE NO. 18-CA-012402 Vv. DIVISION A STATE OF FLORIDA DUVAL COUNTY, FLORIDA; COUNTY COMMISSIONERS DUVAL COUNTY CITY COUNCIL MEMBERS. MAYOR LENNY CURRY HILLSBOROUGH COUNTY, FLORIDA; COUNTY, COMMISSIONERS, MAYOR BOB BUCKHORN Appellee. HILLSBOROUGH COUNTY’S MOTION TO DISMISS COMPLAINT COMES NOW, Hillsborough County, a political subdivision of the State of Florida (“HILLSBOROUGH COUNTY”), by and though undersigned counsel and pursuant to Fla. R. Civ. P. 1.140(b)(6), moves this Honorable Court to dismiss the Complaint filed by Defendant, ROSA H. VALDES, for the following reasons: 1 Defendant filed her Complaint alleging “Abuse of Process”, “Discrimination”, “Fraud”, “Recklessness”, and “Gross Negligence in Duty of Care”, on December 21, 2018. 2. Defendant’s complaint fails to connect the various Florida Statutes with the vague facts she alleges. 3. Consequently, Defendant fails to state a cause of action and her Complaint should be dismissed. 1/8/2019 12:04 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 1 WHEREFORE, HILLSBOROUGH COUNTY moves this Honorable Court to issue an order dismissing the Complaint for the reasons stated. ULL4, Le Lx.ay Kenneth C. Pope, Esquire Sr. Assistant County Attorney Florida Bar No. 894567 Office of the County Attorney Post Office Box 1110 Tampa, Florida 33601-1110 (813) 272-5670 — Fax: (813) 272-5758 Attorney for Defendant, Hillsborough County Service Emails opeK @hillsboroughcounty.org LonerganC@hillsboroughcounty.org HayesDJ@hillsboroughcounty.org CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been furnished by E- Mail to Rosa H. Valdes at whblkredgr813@gmail.com this ge“% day of os 2019. YL LL ty. Lf Kenneth C. Pope 1/8/2019 12:04 PM Electronically Filed: Hillsborough County/13thJ udicial Circuit Page 2