On October 15, 2019 a
Motion-Secondary
was filed
involving a dispute between
Ceron, Stephanie Perez,
and
Bass Pro Outdoor World Llc,
Bass Pro Outdoor World L.L.C.,
Islamorada Fish Company L.L.C,
Pro Outdoor World Llc,
for 3
in the District Court of Broward County.
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Filing # 118271935 E-Filed 12/15/2020 11:31:10 PM
IN THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
STEPHANIE PEREZ CERON,
Plaintiff CASE NO. CACE-19-021489
BASS PRO OUTDOOR WORLD L.L.C.,
ISLAMORADA FISH COMPANY,
Defendants.
REPLY
COMES NOW, the Plaintiffs, by and through their undersigned attorney, and files this
Reply to Defendant, BASS PRO OUTDOOR WORLD, LLC and ISLAMORADA FISH
COMPANY’s Answer and Affirmative Defenses by denying each and every affirmative defense
contained therein and further says that the defenses are so vaguely stated and without particulars,
that they should be stricken as general conclusions.
IT IS HEREBY CERTIFIED that on December 15, 2020, a true and correct copy of the
foregoing has been electronically filed by using the Florida ePortal. I also certify that the
foregoing document is being served either via transmission of Notice of Electronic Filing
generated by the E-Filing Portal or by E-Mail, in accordance with Rule 2.516 of the Florida
Rules of Civil Procedure to all counsel of record identified on the attached Service List.
Respectfully submitted,
/s/Michael A. Hoffma
Michael A. Hoffman, Esq.
FBN: 089549
MICHAEL A. HOFFMAN, ESQ., PA
Attorney for Plaintiff
4000 Hollywood Blvd.
#** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2020 11:31:09 PM.**#*
Suite 725-South
Hollywood, FL 33021
Phone: (954) 665-5290
Fax: (954) 944-1932
Michael@MAHlawyer.com
CERTIFICATE OF SERVICE
Elizabeth M. Rodriguez
Florida Bar No. 821690
erodriguez@fordharrison.com
Ford & Harrison, LLP
One S.E. 3rd Avenue, Suite 2130
Miami, Florida 33131
Telephone: (305) 808-2143
Facsimile: (305) 808-2101
Document Filed Date
December 15, 2020
Case Filing Date
October 15, 2019
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Filing # 118271935 E-Filed 12/15/2020 11:31:10 PM IN THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA STEPHANIE PEREZ CERON, Plaintiff CASE NO. CACE-19-021489 BASS PRO OUTDOOR WORLD L.L.C., ISLAMORADA FISH COMPANY, Defendants. REPLY COMES NOW, the Plaintiffs, by and through their undersigned attorney, and files this Reply to Defendant, BASS PRO OUTDOOR WORLD, LLC and ISLAMORADA FISH COMPANY’s Answer and Affirmative Defenses by denying each and every affirmative defense contained therein and further says that the defenses are so vaguely stated and without particulars, that they should be stricken as general conclusions. IT IS HEREBY CERTIFIED that on December 15, 2020, a true and correct copy of the foregoing has been electronically filed by using the Florida ePortal. I also certify that the foregoing document is being served either via transmission of Notice of Electronic Filing generated by the E-Filing Portal or by E-Mail, in accordance with Rule 2.516 of the Florida Rules of Civil Procedure to all counsel of record identified on the attached Service List. Respectfully submitted, /s/Michael A. Hoffma Michael A. Hoffman, Esq. FBN: 089549 MICHAEL A. HOFFMAN, ESQ., PA Attorney for Plaintiff 4000 Hollywood Blvd. #** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 12/15/2020 11:31:09 PM.**#* Suite 725-South Hollywood, FL 33021 Phone: (954) 665-5290 Fax: (954) 944-1932 Michael@MAHlawyer.com CERTIFICATE OF SERVICE Elizabeth M. Rodriguez Florida Bar No. 821690 erodriguez@fordharrison.com Ford & Harrison, LLP One S.E. 3rd Avenue, Suite 2130 Miami, Florida 33131 Telephone: (305) 808-2143 Facsimile: (305) 808-2101