Memorandum in response to motion for sanctions under Section 768.79, F.S. upon loss of a jury trial in a personal injury action…more
Claims arising from the sale of variable annuities unsuitable to particular investors…more
Southern Baptist Hospital v. Johnston
Denial of NICA benefits affirmed leaving parents of minor child free to pursue remedies in circuit court for medical malpractice for birth injuries…more
The biggest threat to justice in America is the successful propaganda campaign by big business, the health and the insurance industry, and the U.S. Chamber of Commerce against trial lawyers, particularly contingency fee trial…more
Estate of Robert Pippin v Bella Napoli
Defendant driver's employer contends he was not in the course and scope of his employment at the time of an automobile accident that occurred after he delivered a pizza to a customer. This memorandum of law addresses the legal…more
Estate of Pippin v. Bella Napoli NSB,...
Motion for summary judgment on the issue of whether a defendant employee/driver was in the course and scope of his employment when he ran over a pedestrian in a marked crosswalk…more
Motion for Summary Judgment in uninsured motorist coverage action. The uninsured motorist insurer claimed that the injured victim was not an insured under his mother's policy on the grounds that he was not residing with the…more
Third Amended Complaint for money damages for serious injuries caused by catastrophic failure of awning structure on the rear of a strip shopping center due to negligent maintenance of the awning and the roofing system…more
Memorandum of law in opposition to Defendant's motion for protective order precluding taking depositions of corporate officers pursuant to the "apex doctrine"…more
Brief summary of Florida law on landowner liability for motor vehicle accidents…more
Estate of Tommie Lewis v. Werner...
Due to post mortem urine and blood samples positive for the inactive constituent of marijuana, Defendants assert a Florida statutory defense converting Florida's comparative negligence law to contributory negligence where the…more
This is an article by Michael Cerasa, our resident expert in homeowners and property damage claims. The article is about using the Florida building code to prove roof damage claims and being published in the Florida Justice…more
Milian v. Bardmoor Shopping Center
Complaint containing allegations of failure of structure upon shopping center property causing serious permanent injuries and permanent and total disability to invitee…more
Hatcher v. Suwannee Health Care Center
Second amended complaint in action for nursing home negligence, personal injury and wrongful death…more
Bonnie Berens v. Superior Residences
Statement of the Case for arbitrators in an injury claim against an assisted living facility arising from failure to prevent a fall by a patient with severe dementia…more
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