sample motion for summary judgment florida

A motion for summary judgment or a response with exhibits totaling over 10 pages must include an index to the exhibits that lists the exhibit number and title of the exhibit. : 11-20120-CIV-SEITZ/SIMONTON TRAIAN BUJDUVEANU, Plaintiff, vs. DISMAS CHARITIES, INC., ANA GISPERT, DEREK THOMAS and ADAMS LESHOTA Defendants. This will provide you with the opportunity to file an appellate brief. The opportunity to lodge a motion arises when there is no genuine issue of material fact. What this means is that there is no real basis for the parties to disagree on what the facts in the case are. (1)Supporting Factual Positions. Effective May 1, 2021, the new Rule will only require a party to make a legal argument regarding a particular issue. Generally, they say that you have not formally disputed that the debt is valid and that you owe the money. Also, no oral testimony shall be received at the hearing. Challenge the sufficiency of the complaint on its face. This case was handled by Massey & Duffy's employment attorneys and they filed the following summary judgment with the Ocala court. Florida Rules of Civil Procedure. 2d 286, 288 (Fla. 1988); Reaves v. State , 485 So. RESPONSE TO MOTION FOR SUMMARY JUDGMENT A. This allows a party to move for enlargement of time to file a motion for fees prior to the expiration of the 30-day time period outlined in Rule 1.525. A party may move for summary judgment, ident ifying each claim or defense - or the part of each claim or defense - on which summary judgment is sought. We can provide you with the necessary legal guidance when it comes to a motion for summary judgment in Florida. A motion to dismiss is used when a party tries to get a case thrown out. We gave the amended rule a prospective effective date of May 1, 2021. This is different from a standard motion for summary judgment because it doesn't require a detailed explanation of the case. A motion for partial summary judgment only attacks some of the issues in a case, meaning that the entire case will not end once the motion is decided. A summary judgment disposes of the entire case. Outside of those limited circumstances, motions for summary judgments are fairly rare in family law cases. Rule 1.540 - RELIEF FROM JUDGMENT, DECREES, OR ORDERS. Motions for summary judgment in Florida (found under Fla R Civ P 1.510) are used to bring a case to a close or move a case to the next step in the process. endobj It explains why the court should rule in favor of the movant. What is the Florida Rule of Civil Procedure 1.510? What Happens at a Motion for Summary Judgment Hearing? Motion For Summary Judgment Standard in Florida Explained info@cuetolawgroup.com 305.777.0377 Motion For Summary Judgment Standard in Florida Explained January 19, 2022 Cueto Law Group, P.L. Admin. The new rule contemplates adequate time for discovery as one of the prerequisites to a summary judgment. Judgment 2) Pre-Trial Motions: Rule 12(b)(6) and Summary Judgment A. endobj Mainly, a Plaintiff must conclusively prove all the key and essential facts in support of its claim as was held in the leading case of MMP, Ltd. v. Jones, 710 S.W.2d 59, 60 (Tex. Now customize the name of a clipboard to store your clips. PDF-XChange 3.60.0119 (Windows XP); modified using iTextSharp 4.1.6 by 1T3XTDistrict Court, Colorado,Judges,Judge Krieger You can now obtain summary judgment by proving that the adverse party cannot produce admissible evidence to support or dispute a fact. The rule still remains that evidence submitted in support of or in opposition to a MSJ must be admissible in evidence. This means that, according to Federal Rule 56. This meant that a party had to have a great deal of evidence in their favor to meet the Rule's requirements. At the hearing, the court considers evidence that some or all facts of the case have not been disputed. <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[24 0 R]/Type/Page>> Rule 166a (c) concerns motion and proceedings thereon. broward bulldog, inc. and . If a party fails to respond to a motion for summary judgment within the required time frame, a judge may rule in favor of the party that filed the motion. final judgment - damages . On April 29, 2021, the Florida Supreme Court adopted a new summary judgment standard. What Happens If the Motion Is Granted Per Fla R Civ P 1.510? This will result in the case being dismissed, with or without prejudice. MEMORANDUM RE CROSS-MOTIONS FOR SUMMARY JUDGMENT Baylson, J. February 24, 2021 I. Free access to premium services like Tuneln, Mubi and more. This will help the judge better understand the situation and make an informed decision. 3 0 obj P. 1.540. . This is usually done by either objecting to the argument by stating that the evidence presented is insufficient to support the argument or by stating that the information provided is incorrect and should be removed from the motion. The movant must serve the motion for summary judgment at least 40 days before the time fixed for the hearing. Because of this, some lawyers dont bother taking their clients to the hearing. Effective May 1, 2021, the state of Florida adopted the Federal summary judgment standard. Thursday, June 27, 2013. STATE OF FLORIDA ) My name is Ana Gispert. This is often referred to as a negligence claim. BEFORE ME, this date personally appeared the undersigned, who after IN THE UNITED STATES DISTRICT COURT FOR Your motion, which is effectively a dispositive motion, should have been filed in accordance with the summary judgment rule. We've encountered a problem, please try again. 4. 2012 Amendment. What is a Motion for Summary Judgment? This is often the result of the failure of the opposing party to provide sufficient evidence to support their position. By whitelisting SlideShare on your ad-blocker, you are supporting our community of content creators. This can be done by providing additional evidence that shows that the fact in question does not exist or by providing evidence that the allegations have been misinterpreted. In these cases, a motion for summary judgement is brought to have the court order or declare that the father is, indeed, the father. The party being asked to respond to the motion for summary judgment should take the opportunity to review the evidence that was presented in support of the motion for summary judgment and then provide a response to each argument. By accepting, you agree to the updated privacy policy. Clipping is a handy way to collect important slides you want to go back to later. The Following are topics the Florida Supreme Court discussed regarding the new summary judgment standard: The burden of production refers to the quantum of evidence required in order to either negate an essential element of the nonmovants claim or establish that the nonmoving party cannot carry its ultimate burden of persuasion at trial. For example, if the plaintiff files a motion for summary judgment, they ask the judge to rule in their favor. 37 Where endobj Subdivision (c) has been amended to ensure that the moving party and the adverse party are each given advance notice of and, where appropriate, copies of the evidentiary material on which the other party relies in connection with a summary judgment motion. The new Rule 1.510 took effect on May 1, 2021 and applies to MSJs adjudicated on or after May 1, 2021. <> A party may move for summary judgment at any time after the expiration of 20 days from the commencement of the action or after service of a motion for summary judgment by the adverse party. There are several additional, practical factors we would advise you to think about in relation to a summary judgment application. The amended rule also provides that the nonmovants responsewith supporting factual positionbe filedat least 20 days before the hearing. Advocate for Personal Injury victims throughout Broward and Palm Beach Counties. Rule 166a (d) concerns appendices, references and other use of discovery not otherwise on file. Looks like youve clipped this slide to already. The parties can bring certain motions after any judgment, including a summary judgment. Summary Judgment Standard . The Summary Judgment Standard. Previously, a party could submit an affidavit as to why it could not adequately respond to summary judgment, including the need to conduct additional discovery. The defendant is trying to get the case ruled in their favor. The purpose of motion for summary judgment hearing. in and for miami-dade county, florida hermine ricketts and case no. Co. v. Fritz Cos., 210 F.3d 1099 (9th Cir. In addition to good, evidence-based story-telling, the summary judgment motion should also include a succinct title and introduction, which should address whether or not the party is filing a Traditional Summary Judgment as a plaintiff (Rule 166a(a)) or as a defendant (Rule 166a(b)); what kind of summary judgment is requested, Traditional, No Evidence, or a combination of both; and whether the party is seeking a partial or final summary judgment. The provision also provides that a judgement for summary judgment shall be rendered if the deposition transcripts, interrogatory answers, and other discovery responses references or set forth in the motion or response. Motion For Summary Judgment. The Florida Rules of Civil Procedure provide the framework that litigants must follow when pursuing a negligence claim in Florida. Jocelyne Macelloni is a partner at the Coral Gables law firm of Barakat + Bossa and an adjunct professor of law at Nova Southeastern University Shepard Broad College of Law. Description Motion Summary Judgment Sample. SC20-1490, 2020 WL 7778179, at *1 (Dec. 31, 2020). P. Kuhnel v. Sledge, 306 So.2d 194 (1st DCA, 1975) cert. southern district of florida. Pro. Except on leave of court, the adverse party, not later than seven days prior to the day of hearing may file and serve opposing affidavits or other written response. The moving party will argue why the case should be dismissed, and then they'll provide any additional evidence that supports their argument. Once this is complete, the party may move forward with their motion. _____/ plaintiffs' memorandum of law in opposition to defendants' motion for summary judgment Plaintiff has filed a Motion for Summary Judgment which relies on factually inapplicable decisional law; ignores the threshold issue of legal standing; fails to justify the striking of Defendants contesting Answer; and purports . This can significantly shorten the length of a case, as additional evidence can often be used to show that a particular fact exists or doesn't exist. Motion for Summary Judgment (Doc. 1 0 obj Smith is the company's sole offi cer, director, and . The benefit of Summary Judgments is that they save clients a ton of money, especially in civil litigation outside of family law cases. endobj the Florida Deceptive and Unfair Trade Practices Act, Florida Stat. Case Filed Jan 12, 2021 Case Status Open County Palm Beach County, FL Filed Date Jan 22, 2061 Type Assn Lien Foreclosure = < $50K MOTION MOTION FOR LEAVE TO AMEND THIER ANSWER AND AFFIRMATIVE DEFENSES Case Name A AFFORDABLE PLUMBING SERVICE INC V BELLE HARBOUR PROPERTIES LLC Case # 50-2020-CA-007318-XXXX-MB Case Filed Jul 13, 2020 Case Status Open Thursday, April 30, 2015. In Re: Amendments to Florida Rule of Civil Procedure 1.510, No. Ms. Macelloni represents businesses and business owners in state and federal courts throughout the country and in various practice areas including corporate disputes, asset recovery, secured transactions, factoring and other UCC-related disputes. 9 0 obj This means that, instead of waiting for the other party to provide a response to the lawsuit, the party may move the case forward by presenting the necessary evidence. Contents of a motion for summary judgment. 1 In re: Amendments to Fla. Rule of Civil Proc. 174), in response to which Defendant Universal Processing Services of Wisconsin, LLC ("UPS") filed a Memorandum in Opposition (Doc. Under the new rule, if the nonmoving party must prove X to prevail [at trial], the moving party at summary judgment can either produce evidence that X is not so or point out that the nonmoving party lacks the evidence to prove X.1. These can be summarized in the final set of bullet points: AtLegal writing experts,we would be happy to assist in preparing anylegal documentyou need. showing that the materials cited do not establish the absence or presence of a genuine dispute or that an adverse party cannot produce admissible evidence to support the fact. Motion for Summary Judgment example is a request that a court rules on a case even if the case hasnt been to trial. In this scenario, the claimant should not be making an application for summary judgment. During this time, the party being asked to respond to the motion should gather any documents that will be relevant to their response and send them to the court. SOUTHERN DISTRICT OF FLORIDA MIAMI DIVISION www.flsb.uscourts.gov IN RE: Case No. "halfway house," on July 28, 2010 until his release date of January 31, 2011. A party opposing summary judgment must do more than simply show that there is some metaphysical doubt as to the material facts. As can be seen, the Federal Summary Judgement standard is in the best interest of the state because it will promote and secure the just, speedy, and inexpensive determination of every action. <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[27 0 R]/Type/Page>> Affidavit in support of motion for summary judgment 1. If the father is disputing the DNA, he probably has something mentally wrong with him or a serious need to try to avoid child support at all costs. These motions are rarely contested; however, it does happen on occasion. The creator of the affidavit, the affiant, must swear they are over 18 years old and competent to give the affidavit. This change is expected to impose a less restrictive standard for parties moving for summary judgment in Florida state courts. I am over the age of 18 years and not laboring In your own separately numbered paragraphs, state the facts, providing dates. A plaintiff may be denied summary judgment under Florida law in several circumstances, including: When a case is settled, the parties will then have the opportunity to enter their final judgment. A motion for summary judgment is a request made by a party asking the court to decide all or part of a lawsuit without going to trial because there's no dispute about the key facts of the case. Instead, there must be evidence on which a jury could reasonably find for the nonmoving party. Instead, it simply requires proof that the other party doesn't have enough evidence to prove their case. Many arguedthat this prevented just and speedy trials and led to a lot of back and forth between the parties. ATTORNEYS FEES FOR BAD FAITH AFFIDAVITS. OS-00S162-CI-ll THE CERTIFICATEHOLDERS CWABS, INC. . <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[20 0 R]/Type/Page>> The court classified this as a critical requirement, and explained that, in order to comply, a trial court must do more than make a conclusory statement that there is or is not a genuine dispute as to material fact. In a legal dispute, motions are used to bring a case to a certain conclusion. 6 0 obj The summary judgment procedure is set forth in Florida Rule of Civil Procedure Rule 1.510. It is a final ruling in the case, and no further testimony or evidence is heard. A summary judgment motion is heavily steeped in legal arguments, primarily case law. Accept that there are no disputed facts, but dispute the movants recitation of the law. 5. Florida's Second District Court of Appeal recently issued a decision that serves as a reminder not to take for granted a proposition that most practicing attorneys regularly encounter: a motion for summary judgment must be supported by competent evidence, and an affidavit that does little more than mimic the motion for summary judgment will not Ledezma Law Firm. This will provide the party with the opportunity to explain why they believe the final judgment should be amended. The rule is amended to adopt almost all the text of Federal Rule of Civil Procedure 56. 1.510, 309 So. P. 166a. 15 0 obj {width:40px; Like the filing party, the opposing party will submit a statement of facts serving as a roadmap to their evidence which shows that issues of fact remain. Any response to the motion for summary judgment is due no less than 7 days before the hearing. Defendants' summary judgment motion was hear d March 31, 2010. However, a party can renew its MSJ under the new rule. endobj A motion for summary judgment in a civil case is a motion to essentially dismiss the case. So, to successfully defeat a summary judgment motion, the opposing party will want to submit evidence showing that there are still issues of fact in dispute. A motion for summary judgment hearing is held to determine whether the party seeking summary judgment has met its burden. However, they must still support their assertion by: Simply put, this means that the mere existence of some alleged factual dispute between the parties will not defeat an otherwise properly supported motion for summary judgment. (Anderson, 477 U.S. at 247-48.). Rules. Can you File a Motion for Summary Judgment in Florida Before Discovery? <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[18 0 R]/Type/Page>> If they have, the judge will sign an order that prevents the party being asked to respond to the motion from further arguing the issue in question. A response to motion for summary judgment is a formal response to the motion filed by the party moving for summary judgment. The party being asked to respond to the motion will have an opportunity to argue that the other party has not met the necessary requirements. This can be a complicated process, but a skilled attorney can usually explain the process to the party and provide them with the necessary legal guidance. P. 1.540. The LexisNexis Editorially Selected Briefs, Pleadings & Motions collection can help you review how similar litigation developed, study how other legal professionals have framed arguments on your topic, and find template models for your own work. : 11-20120-CIV-SEITZ/SIMONTON I can recommend a site that has helped me. "A pleading is only considered a sham when it is inherently false and clearly known to be . B. What is a Motion for Summary Judgment Per Florida Law. southern district of florida fort lauderdale division eloy rojas mamani, et al., plaintiffs, v. gonzalo daniel snchez de . What is Motion for Summary Judgment in a Civil Case? "Florida Rule of Civil Procedure 1.530 has been consistently construed to authorize rehearings of orders and judgments which are final in nature." (See Deal v. Deal (2001) 783 So.2d 319, 321.) Powered bySymatech Labs Ltd, IN THE ________ JUDICIAL DISTRICT COURT IN, Introduction It is important that all makeup, Introduction A consulting partnership agreement template entails, Landlords consent: what happens when it goes. The following overview provides 10 major changes that every busy practitioner should know about. Motions for partial summary judgment can thus help narrow the issues to be decided at trial. Before the Court is Defendants motion for summary judgment (DE 101) ("SJ Motion") and Plaintiffs cross-motion for [partial] summary judgment (DE 118) ("Cross Motion"). You will have an opportunity to reply to whatever they ultimately raise. The court also advised appellate courts not to disregard the evidence supporting the motion, also adding that although a reviewing court must consider all the summary judgment evidence on file, in some cases that review will effectively be restricted to the evidence contrary to the motion. City of Keller v. Wilson, 168 S.W.3d 816, 824-8. A case can be disposed of prior to trial when there is no evidence for the claims alleged or when there is no issue of material fact, and the movant is entitled to judgement as a matter of law. This usually occur after a DNA test of both the child and the father. NEW FLORIDA MOTION FOR SUMMARY JUDGMENT STANDARD 1.510 Effective May 1, 2021, the state of Florida adopted the Federal summary judgment standard. A motion for summary judgment should be granted if the 'pleadings, depositions, " answers to interrogatories and admissions onfile, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to judgment as a matter of law . Motion to Strike Sham Pleading in Florida Civil Cases under Fla. R. Civ. How to Defeat the Motion to Amend Final Judgment in Florida. xXn}W{yHZ[r,`49H /:_oYHANU9y8!7U&$J{'/KhYM=GUDcZE]4l|kJN7rI)m&/Zg&^q:. When this is the case, the party who opposes the final judgment will then have the opportunity to file a motion to amend the final judgment. << /Length 5 0 R /Filter /FlateDecode >> At the hearing, each party will be given a certain amount of time to reiterate their argument in front of the judge. <> needed; number all your paragraphs. being first duly sworn hereby state, as follows: MOTION FOR SUMMARYJUDGMENT 17 0 obj A "judgment" is not necessary. u.s. department of justice . However, to move forward with a motion for summary judgment, a party must first file a summons and complaint with the court. #short_code_si_icon img <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[22 0 R]/Type/Page>> Opposing affidavits must be made on personal knowledge, set out facts that would be admissible in evidence, and must show that the affiant or declarant is competent to testify on the matters stated therein. I.R.S., 2 F.3d 366, 369 (11th Cir.1993)). 3. This can often mean that the party being asked to respond to the motion will only need to engage in a legal argument regarding a particular issue. For those litigating in federal courts, the rule is nothing new; in fact, Rule 1.510 of the Florida Rules of Civil Procedure adopts most of its federal counterpart verbatim. The court may also hold an offending party or attorney in contempt or impose other appropriate sanctions. COUNTY OF BROWARD ) endobj In the family law arena, their usage is fairly restricted to parentage cases where one party disputes which father belongs to the child. DISMAS CHARITIES, INC., ANA GISPERT, Florida's Civil Rules also allow for a motion to strike "sham" pleadings. In an effort to impress, you tell him about Florida's idiosyncratic "sham pleadings&# . Motions for summary judgment can also seek relief for the entire case - meaning that the whole lawsuit would be resolved without having to conduct a trial. This means that the judge has agreed that the party has presented sufficient evidence to support their argument and will result in an automatic judgment in favor of the party who filed the motion. It provides that the discovery products that are not on file with clerk can be used as evidence for the motion of summary judgment. Further, there must not be real and genuine issues of fact that ought to be resolved at a trial. DEREK THOMAS and ADAMS LESHOTA Yet Defendant still refused to answer Plaintiff's complaint and discovery. 5. S.D. Case 1:11-cv-20120-PAS Document 87-1 Entered on FLSD Docket 12/27/2011 Page 1 of 62 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO. 13 0 obj B.J.F., 530 So. TRAIAN BUJDUVEANU, Be concise when youre preparing the evidence in support of your application. The decision usually depends on the lawyer, the client, and the nature of the case. If you want to avoid your case being allocated to a particular track prior to a summary judgment. Rule 56 of the Federal Rules of Civil Procedure mandates the entry of summary judgment "against a party who fails to make a showing sufficient to establish the existence of an element essential to that party's case, and on which that party will bear the burden of proof at trial." Celotex Corp. v. Catrett An out-of-state lawyer is on the phone. _____/ motion for reconsideration of court's order denying defendants' motion for summary judgment with regard to document 22 12 0 obj Moving back to family law cases, we would see such motions when paternity has been established, and we want the court to order Mr. X is the father. Either way, the movant must prove two things to be successful: R. Civ. The format of a motion for summary judgment in Florida will vary based on the rules being used, but the goal is typically the same. The amendment to subdivision (c) will require timely service of opposing affidavits, whether by mail or by delivery, prior to the day of the hearing on a motion for summary judgment. The "federal summary judgment standard" refers to the principles announced in Celotex Corp. v. Catrett, 477 U.S. 317 (1986), Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986), and Matsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986), and more generally to case law interpreting Federal Rule of Civil Procedure 56. Towards the end of his sentence, Plaintiff was transferred to Dismas, a In the past, the Florida Rule of Civil Procedure 1.510 was considered very stringent. Specifically, If the nonmoving party must prove X to prevail [at trial], the moving party at summary judgment can either produce evidence that X is not so or point out that the nonmoving party lacks the evidence to prove X.Bedford v. Doe, 880 F.3d 993, 996-97 (8th Cir. The time frame applicable to a motion of summary judgment. Pro. When a motion is granted per Fla R Civ P 1.510, it means that the party moving for summary judgment has been successful. No express deadline has been set for filing a reply. See, e.g., Miccosukee Tribe of Indians of Florida v. United States, 516 F.3d 1235 (11th Cir. 8:17-cv-2896-T-02AAS PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT AND MOTION TO EXCLUDE CERTAIN OPINIONS OF DEFENDANT'S EXPERT AND INCORPORATED MEMORANDUM OF LAW Plaintiffs ROBERT L. VAZZO . Plaintiff pled guilty to charges of conspiring to illegally export military Case 1:11-cv-20120-PAS Document 87-1 Entered on FLSD Docket 12/27/2011 Page 1 of 62 16-61289-civ-altonaga . Florida judges for many years have given rule 1.510 a broad interpretation regarding what was a genuine issue. For example, parties may seek summary judgment on some issues, claims, or defenses in a case to help strengthen their position in the litigation and leverage a settlement from the other side. Artificial intelligence - the futuristic world, Meeting 2. <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[19 0 R]/Type/Page>> in the county court, in and for 1999). He assures you that the complaint's factual allegations are demonstrably false and tells you that he wants to move for summary judgment as soon as possible. IN AND FOR PINELLAS COUNTY, FLORIDA CIVIL DIVISION THE BANK OF NEW YORK AS TRUSTEE FOR, CASE NO. All rights reserved. _____/ CASE NO. (quoting Miscavige v. According to Rule 166a, a motion for summary judgment should be filed and served no less than 21 days before the hearing. Effective May 1, 2021, Florida is adopting a new summary judgment standard to comport with federal law. endobj Essentially, the summary judgment standard provided for in this rule shall be construed and applied in accordance with the federal summary judgment standard articulated inCelotex Corp. v. Catrett, 477 U.S. 317 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1976); andMatsushita Electric Industrial Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) [(the Celotextrilogy)].In re Amends. When that happens, the moving party usually tries to claim that the fact that the responding party is disputing isnt material. Once the triggering point is met, then the moving party is entitled to judgment as a matter of law. Which usually means that they should win. It is important to note that a motion for summary judgment does not guarantee that the judge will issue an order that prevents the other party from continuing to argue the issue in question. The judge will then decide whether or not to amend the final judgment. This amount of time varies by state, but is usually around 21 days. Additionally, in pending cases that have already been briefed but not yet decided, the court should allow the parties to adjust the briefings to comply with the new rule. This includes such as applying to have a claim or defense struck out should be used. 2.516. If you are the defendant in the proceedings, check whether there are any documents. Both scenarios use a similar format, but they have different goals. 2018). Response to a motion for summary judgment. DUVAL COUNTY, FLORIDA JOHN PARSONS, Plaintiff, vs. CITY OF JACKSONVILLE, FLORIDA, a municipal corporation and political subdivision of the State of Florida, Defendant. Now, the burden on summary judgment lies with the party that has the burden at trial. Rule . source: sections 55.081 and 55.10, florida statutes (2007) form notes are for informational purposes only and may not completely describe requirements of florida law. If you're struggling to understand a Florida motion for summary judgment or need legal advice, then a consultation with an experienced Florida lawyer may be exactly what you need. <>>>/Parent 2 0 R/MediaBox[0 0 612 792]/Contents[28 0 R]/Type/Page>>

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