Motion for Summary Judgment

MOT, NOT, BRIEF
Corey Lightner, Attorney at Law
Bar No. 85-455
Miami, Florida 33176
305-456-7890

ATTORNEY FOR PLAINTIFF

IN THE CIRCUIT COURT OF THE ELEVENTH JUDICIAL CIRCUIT
INANDFOR ­­­MIAMI-DADE COUNTY, FLORIDA

WILMA MAPLES,

Plaintiff, CIVIL DIVISION vs. CASE: 13-2014-159753 DEPT. NO: XVII DOCKET NO:
WE CARE FOR YOU HOSPITAL AND
REHABILITATION CENTER,
1-5 DOES,
1-5 ROES, MOTION FOR SUMMARY JUDGMENT, NOTICE, AND BRIEF

Defendants.
___________________________/

MOTION FOR SUMMARY JUDGMENT COME NOW, PLAINTIFF, by and through her attorney of record, Corey Lightner, Esq.. of YOUNG’S LAW FIRM, and hereby files their Motion for Summary Judgment. The rule governing this matter is Rule 1.510(c) of the Florida Rules of Civil Procedure.
This motion is made and based upon the Points and Authorities attached herein, the papers and any oral argument that may be entertained at the time of the hearing on this matter.
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Dated this 7th day of November, 2014.

By ________________________
Corey Lightner, Esq.
Bar No. 85-455
123 Main Street
Miami, Florida 33176
305-456-7890
ATTORNEY FOR PLAINTIFF

NOTICE OF MOTION

TO: WE CARE FOR YOU HOSPITAL AND REHABILITATION CENTER, Defendant; and

TO: JAMES JOHNSON, its counsel.

YOU, AND EACH OF YOU, WILL PLEASE TAKE NOTICE that the undersigned will bring the foregoing Motion for Summary Judgment on for hearing before the above-titled Court in Dept. 2, on the 5th day of December, 2014, at the hour of 10:00 a.m. or soon thereafter as counsel can be heard.
Dated this 7th day of October, 2014.
___________________________
Corey Lightner, Esq. ATTORNEY FOR PLAINTIFF

TRIAL BRIEF
FACTS OF THE CASE On or about February 4, 2014, Plaintiff, Wilma Maples, a 65 year old woman, was admitted to the defendant-hospital, We Care for You Hospital and Rehabilitation Center, to undergo a total knee replacement on her left leg due to her suffering from osteoarthritis. The surgery was