On July 08, 132 a
was filed
involving a dispute between
Shelatz, Alyn,
Shelatz, Daniel,
and
Port Charlotte Hma Llc,
for Premises Liability - Commercial
in the District Court of Charlotte County.
Preview
Filing # 97838323 E-Filed 10/24/2019 04:00:41 PM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
DANIEL SHELATZ and
ALLYN SHELATZ,
Plaintiffs,
vs. Case No.: 18000223CA
PUNTA GORDA HMA, LLC,
a Florida limited liability company, d/b/a
BAYFRONT HEALTH PUNTA GORDA,
Defendant.
/
RULE 1.520 MOTION FOR JURY TO BE TAKEN TO THE PREMISES
Plaintiffs respectfully move this honorable Court, pursuant to Fl. R. Civ. P. 1.520, to allow the
jury of the trial of this matter on liability, which is set for November 5, 2019, to be taken to Defendant’s
premises to view the condition that Plaintiffs allege to be hazardous and essentially is the crux of this
litigation. Defendant’s premises is within one mile of the courthouse, and Plaintiffs believe it should
take less than one hour to accomplish.
WHEREFORE, Plaintiffs respectfully request this honorable Court issue an Order granting
Plaintiffs’ request to allow the jury to be taken to the premises during the trial of this matter on liability.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 24" day of October 2019, a true and correct copy of the
foregoing has been furnished via electronic mail to A. Kevin Houston, Esquire and Louis J. La Cava,
Esquire, LA CAVA & JACOBSON, P.A., 2590 Northbrook Plaza, Suite 307, Naples, FL 34119 at the
following primary and secondary emails: khouston@lacavajacobson.com llacava@lacavajacobson.com
kkeyte@lacavajacobson.com leddings@lacavajacobson.com
FLORIN, GRAY, BOUZAS, OWENS, LLC
/s/Hunter A. Higdon
CHRISTOPHER D. GRAY, ESQUIRE
Florida Bar No.: 902004
Primary: chris@fgbolaw.com
Secondary: debbie@fgbolaw.com
WOLFGANG M. FLORIN, ESQUIRE
Florida Bar No.: 907804
wolfgang@fgbolaw.com
HUNTER A. HIGDON, ESQUIRE
Florida Bar No.: 85963
hunter fgbolaw.com
16524 Pointe Village Drive, Suite 100
Lutz, FL 33558
Telephone (727) 254-5255
Facsimile (727) 483-7942
Attorneys for Plaintiff
Document Filed Date
November 02, 2023
Case Filing Date
July 08, 132
Category
Premises Liability - Commercial
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Filing # 97838323 E-Filed 10/24/2019 04:00:41 PM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION DANIEL SHELATZ and ALLYN SHELATZ, Plaintiffs, vs. Case No.: 18000223CA PUNTA GORDA HMA, LLC, a Florida limited liability company, d/b/a BAYFRONT HEALTH PUNTA GORDA, Defendant. / RULE 1.520 MOTION FOR JURY TO BE TAKEN TO THE PREMISES Plaintiffs respectfully move this honorable Court, pursuant to Fl. R. Civ. P. 1.520, to allow the jury of the trial of this matter on liability, which is set for November 5, 2019, to be taken to Defendant’s premises to view the condition that Plaintiffs allege to be hazardous and essentially is the crux of this litigation. Defendant’s premises is within one mile of the courthouse, and Plaintiffs believe it should take less than one hour to accomplish. WHEREFORE, Plaintiffs respectfully request this honorable Court issue an Order granting Plaintiffs’ request to allow the jury to be taken to the premises during the trial of this matter on liability. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 24" day of October 2019, a true and correct copy of the foregoing has been furnished via electronic mail to A. Kevin Houston, Esquire and Louis J. La Cava, Esquire, LA CAVA & JACOBSON, P.A., 2590 Northbrook Plaza, Suite 307, Naples, FL 34119 at the following primary and secondary emails: khouston@lacavajacobson.com llacava@lacavajacobson.com kkeyte@lacavajacobson.com leddings@lacavajacobson.com FLORIN, GRAY, BOUZAS, OWENS, LLC /s/Hunter A. Higdon CHRISTOPHER D. GRAY, ESQUIRE Florida Bar No.: 902004 Primary: chris@fgbolaw.com Secondary: debbie@fgbolaw.com WOLFGANG M. FLORIN, ESQUIRE Florida Bar No.: 907804 wolfgang@fgbolaw.com HUNTER A. HIGDON, ESQUIRE Florida Bar No.: 85963 hunter fgbolaw.com 16524 Pointe Village Drive, Suite 100 Lutz, FL 33558 Telephone (727) 254-5255 Facsimile (727) 483-7942 Attorneys for Plaintiff