MOTION DEFENDANT'S MOTION FOR SANCTIONS AGAINST PLTF FOR FAILURE TO COMPLY WITH DISCOVERY ORDERS

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On May 31, 100 a premises liability commercial case was filed by Andre H Pacini, represented by David S Magram, Richard A Bolton, and Robert C Rogers, against Lands Of The President Condominium Three Inc The, and Lands Of The President Condominium Two Inc, represented by Kristina L Alexander, in the jurisdiction of Palm Beach County. Judge Jaimie R. Goodman presiding.

                        
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                          Filing # 118705791 E-Filed 12/23/2020 04:25:23 PM

IN THE CIRCUIT COURT IN THE 15TH JUDICIAL CIRCUIT COURT
IN AND FOR PALM BEACH COUNTY, STATE OF FLORIDA

CIVIL DIVISION
ANDRE H. PACINI, CASE NO.: 50-2017- CA-012307XXXX MB
Plaintiff,
Vv.
THE LANDS OF THE PRESIDENT
CONDOMINIUM TWO, INC., a
Florida Not for Profit Corporation,

Defendant.
/

DEFENDANT’S MOTION FOR SANCTIONS AGAINST PLAINTIFF FOR FAILURE TO
COMPLY WITH DISCOVERY ORDERS

COMES NOW, Defendant, THE LANDS OF THE PRESIDENT CONDOMINIUM TWO, INC.,
(Defendant), by and through the undersigned attorney and pursuant to Florida Rule of Civil
Procedure 1.380 files this Motion For Sanctions Against Plaintiff for Failure to Comply with this
Court’s Orders on Defendant’s Motion to Compel Discovery issued June 13, 2019 and
Defendant’s Motion to Compel Discovery Responses to Defendant’s Request for Production of
Social Media Discovery issued on December 9, 2020, and states as follows:
STATEMENT OF RELEVANT FACTS
1. Claimant commenced this …