`
`IN THE CIRCUIT COURT OF THE 17TH
`IN AND FOR
`JUDICIAL CIRCUIT
`BROWARD COUNTY, FLORIDA
`
`SHINER LAW GROUP, P.A., a
`Florida Profit Corporation,
`
`InterpleaderPlaintiff,
`
`CASE NO.: CACE-24-011582
`
`V N
`
`EUROSPINE INSTITUTE, LLC, a Florida Limited
`Liability Company; NORTH BROWARD HOSPITAL
`DISTRICT d/b/a BROWARD HEALTH a Florida Not For
`BROWARD
`NORTH
`Profit
`Corporation;
`RADIOLOGISTS, P.A.,
`a
`Florida
`Profit
`Corporation;
`PHOENIX EMERGENCY MEDICINE OF BROWARD,
`LLC, a Florida Limited Liability Company; ANESCO
`NORTH BROWARD, LLC, a Florida Limited Liability
`Company; TIFFANY COOLEY, an individual;and SHINER
`LAW GROUP, P.A., a Florida Profit Corporation,
`
`Defendants.
`
`INTERPLEADER PLAINTIFF'S REPLY TO DEFENDANT, NORTH BROWARD
`HOSPITAL DISTRICT D/B/A BROWARD HEALTH'S ANSWER TO PLAINTIFF'S
`INTERPLEADER
`
`COMES NOW, InterpleaderPlaintiff,SHINER LAW GROUP, P.A. ("Plaintiff'),by and
`
`through undersignedcounsel and in accordance with the Florida Rules of Civil Procedure, and
`
`hereby respectfullyfiles this Reply to Defendant, NORTH BROWARD HOSPITAL DISTRICT
`
`d/b/a BROWARD HEALTH's Answer to Plaintiffs InterpleaderComplaint, and, in support
`
`therefore,states as follows:
`
`1.
`
`Plaintiff denies each and every allegationcontained in the Defendant's Affirmative
`
`Defenses and demands strict proofthereof.
`
`2.
`
`Additionally,each of Defendant's Affirmative Defenses fail because they do not
`
`allegesufficient factual support and amount to mere conclusions of law. See Cady v. Chevy Chase
`
`Sau & Loan, Inc., 528 So. 2d 136, 137 (Fla.4th DCA 1988) ("Certaintyis requiredwhen pleading
`
`*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/18/2024 05:40:51 PM.****
`
`
`
`Shiner Law Group, P.A. v. Neurospine Institute, LLC, et al
`Plaintiff's Reply to North Broward Hospital District's Answer to Interpleader
`Page 2
`
`defenses, and pleadingconclusions of law unsupportedby allegationsof ultimate fact is legally
`
`insufficient.");Thompson v. Bank ofN.Y., 862 So. 2d 768, 771 (Fla.4th DCA 2003); Walkerv.
`
`Walker, 254 So. 2d 832, 834 (Fla.1st DCA 1971) ("A plaintiffis as much entitled to be aware of
`
`the ground upon which it is claimed he should not recover as is a defendant to be apprisedof the
`
`basis of the plaintiff'sclaim. The degree of certaintyrequiredin a pleading is that the pleader
`
`must set forth the facts in such a manner as to reasonablyinform his adversaryofwhat is proposed
`
`to be proved in order to provide the latter with a fair opportunityto meet it and prepare his
`
`evidence.").
`
`3
`
`Defendant's Affirmative Defenses are pled as legallyinsufficient conclusions of
`
`law, are too vaguely pled to constitute a defense, or are not a legallyrecognizableaffirmative
`
`defense in this action.
`
`CERTIFICATE OF SERVICE
`
`WE HEREBY CERTIFY that a true and correct copy ofthe foregoingwas sent via E-Filing
`on this 18th day of November 2024, to the following:
`SAGE LAW OFFICE
`Attorneysfor North Broward Hospital
`Attn: Edward M. Harvey, Esq.
`1300 Sawgrass Corporate Parkway, Suite 140
`Sunrise,Florida 33323
`T: (954) 835-0302
`eharvey@sagelaw.com
`
`Respectfullysubmitted,
`
`SHINER LAW GROUP, P.A.
`Attorneysfor InterpleaderPlaintiff
`7800 Congress Avenue, Suite 108
`Boca Raton, Florida 33487
`P: (561) 777-7700 + F: (561)368-3364
`Primary: Litigation@ShinerLawGroup.com
`
`By:
`
`/s/ David I. Shiner
`DAVID I. SHINER
`Florida Bar No.: 572721
`
`
`
`Shiner Law Group, P.A. v. Neurospine Institute, LLC, et al
`Plaintiff's Reply to North Broward Hospital District's Answer to Interpleader
`Page 3
`
`STRATTON A. SMILEY
`Florida Bar No.: 111780
`
`
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