MOTION TO COMPEL - PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND MOTION FOR SANCTIONS

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                           Filing # 171682302 E-Filed 04/24/2023 07:10:35 PM


                  IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
                          IN AND FOR PALM BEACH COUNTY, FLORIDA

         MING JAI LI,

                        Plaintiff,                             CASE NO.: 502000CA007979XXXXMB
         vs.

         EUGENE WILLIAM HANNA, an
         Individual and TRANSYSTEMS, INC.,
         a Florida Profit Corporation

                     Defendants.
         _________________________________/

                             PLAINTIFF’S MOTION TO COMPEL DISCOVERY
                                    AND MOTION FOR SANCTIONS

                COMES NOW Plaintiff, Ming Li, by and through undersigned and pursuant to Florida

         Rules of Civil Procedure 1.350 and 1.380, hereby moves this Court for an order imposing sanctions

         and compelling Defendants to produce materials responsive to Plaintiff’s First Requests for

         Production No. 18 and, in support th…