REPLY/RESPONSE

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On July 8, 1974 an other negligence case was filed by Jane Doe, represented by David J Brevda, against Boca Raton Regional Hospital Inc Dba Boca Raton Reginal Hospital, and Devon Briganti, represented by Julie N Pagni, Osvaldo J Ortega, and Rose Marie Antonacci-Pollock, in the jurisdiction of Palm Beach County. Judge John S. Kastrenakes presiding.

                        
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                          Filing # 128902791 E-Filed 06/16/2021 04:37:45 PM

IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT OF FLORIDA, IN AND

FOR PALM BEACH COUNTY
JANE DOE, GENERAL JURISDICTION DIVISION
Plaintiff, Case No: 50-2020-CA-014445-XXXX-MB

Vv.

BOCA RATON REGIONAL HOSPITAL,
INC. d/b/a BOCA RATON REGIONAL
HOSPITAL, and DEVON BRIGANTI,

Defendants.

PLAINTIFEF’S RESPONSE IN OPPOSITION TO DEFENDANT’S, BOCA RATON
REGIONAL HOSPITAL’S, MOTION TO DISMISS

Plaintiff, JANE DOE, by and through the undersigned counsel, hereby responds in
annosition to the Defendant’s, BOCA RATON REGIONAT, HOSPTIAL, INC’s, Motion to
Dismiss, as states as follows:

I. INTRODUCTION AND FACTUAL BACKGROUND

This lawsuit stems from a heinous rape at BOCA RATON REGIONAL HOSPITAL on or
around October 16, 2020, perpetrated by an ED Tech employed by the Defendant, BOCA RATON
REGIONAL HOSPITAL. As addressed in the Complaint, DEVON BRIGANTI was the Plaintiff's
assigned ED TECH on the night of October 15, 2020 and early morning of Oct…