throbber
Filing # 160133355 E-Filed 10/27/2022 04:34:53 PM
`
`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`
`SHERON JOHNSON,
`
`Plaintiff,
`
`v.
`
`RONALD A. FIGUEREDO, M.D.
`and SMART SHAPE BODY, LLC,
`
`Defendants.
`
`/
`
`Case No.: 22-CA-001512
`Division: C
`
`AMENDED MOTION TO A_MEND AMENDED COMPLAINT
`
`Plaintiff, SHERON JOHNSON, by and through the undersigned counsel, submits this
`
`Amended Motion to Amend Amended Complaint pursuant to Rule l.l90(a) Florida Rules of
`
`Civil Procedure and states as follows:
`
`1.
`
`A copy of the proposed 2nd Amended Complaint is attached hereto .
`
`2.
`
`Plaintiff proposes to amend the Complaint in the following manner to add claims against
`
`an additional Defendant, SMART SHAPE, LLC and LEONARD LURIA, M.D., and to
`
`add a claim for Apparent Agency against Defendant, SMART SHAPE BODY, LLC.
`
`3.
`
`This case is still in the discovery phase and no trial date has been set.
`
`4.
`
`The Defendants will not be unduly prejudiced by this proposed amendment.
`
`CERTIFICATE OF SERVICE
`THE UNDERSIGNED HEREBY CERTIFIES that a the and correct copy of the
`
`above and foregoing has been electronically filed through the Florida E-File Portal and
`
`furnished via E-Mail this 27**' day of October, 2022, to: Christopher J . Schulte, Esq., Weekley
`
`Schulte Valdes Murman Tonelli, Counsel for Defendants, RONALD A. FIGUEREDO,
`
`MD. and SMARTSHAPE BODX LLC, sen/ice@wsvlegal.com, npservice@wsvleg.aI.com.
`
`l
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 1
`
`

`

`PALMER LOPEZ P.A.
`
`Is/Joseph K. Lopez. Jr.
`Joseph K. Lopez Jr.
`Florida Bar No.: 106080
`Martin W. Palmer
`Florida Bar No.: 0150347
`Cole C. Masterson
`Florida Bar No.: 1011928
`17543 Darby Lane
`Lutz, Florida 33558
`Phone:
`813-506-5651
`Facsimile:
`813-506-5654
`E-mail: service@palmerlopez.com
`
`2
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 2
`
`

`

`IN THE CIRCUIT COURT OF THE THIRTEENTH JUDICIAL CIRCUIT
`IN AND FOR HILLSBOROUGH COUNTY, FLORIDA
`
`SHERON JOHNSON,
`
`Plaintiff,
`
`v.
`
`RONALD A. FIGUEREDO, M.D.,
`LEONARD LURIA, M.D.,
`SMART SHAPE BODY, LLC, and
`SMART SHAPE, LLC,
`
`Defendants.
`
`/
`
`Case No.: 22-CA-001512
`Division: C
`
`SECOND AMENDED COMPLAINT
`
`Comes now the Plaintiff, SHERON JOHNSON, by and through the undersigned attorneys,
`
`and files this Second Amended Complaint against Defendants, RONALD A. FIGUEREDO, M.D.
`
`(hereinafter, "DR. FIGUEREDO"), LEONARD LURIA, M.D. (hereinafter, "DR. LURIA"),
`
`SMART SHAPE BODY, LLC (hereinafter, "SMART SHAPE BODY"), and SMART SHAPE,
`
`LLC (hereinafter, "SMART SHAPE"), and alleges as follows:
`
`GENERAL ALLEGATIONS
`
`1. This is a cause of action for damages in excess of $30,000.00.
`
`2. At all material times, Plaintiff, SHERON JOHNSON, was a resident of Prince George's
`
`County, Maryland.
`
`3. Upon information and belief, at all material times, Defendant, DR. FIGUEREDO, was a
`
`licensed physician authorized to and practicing medicine in Hillsborough County, Florida.
`
`4.
`
`Upon information and belief, at all material times, Defendant, DR. LURIA, was a licensed
`
`physician authorized to and practicing medicine in Hillsborough County, Florida.
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 3
`
`

`

`5. Upon information and belief, at all material times, Defendant, SMART SHAPE BODY, was
`
`a Florida limited liability company authorized to and doing business in Hillsborough County,
`
`Florida.
`
`6. Upon information and belief, at all material times, Defendant, SMART SHAPE, was a Florida
`
`limited liability company authorized to and doing business in Hillsborough County, Florida.
`
`7. All conditions precedent, including those required by pre-suit and pursuant to Chapter 766 of
`
`Florida Statutes have been met and Counsel for the Plaintiff certifies that a reasonable
`
`investigation into the underlying matter has been performed and a good faith basis for each of
`
`the Lmderlying claims exists at this time pursuant to Section 766.104(1), Florida Statutes.
`
`COUNT I .- MEDICAL NEGLIGENCE as to Defendant, DR. FIGUEREDO
`
`8. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`9. On or about February 23, 2021, Plaintiff; SHERON JOHNSON, underwent liposuction
`
`surgery performed by Defendant, DR. FIGUEREDO, at Co-Defendants, SMART SHAPE
`
`BODY and SMART SHAPE's, facility located at 5352 North Habana Avenue, Suite C-D in
`
`Tampa, Florida.
`
`10. At all material times, Defendant, DR. FIGUEREDO, owed Plaintiff, SHERON JOHNSON,
`
`a duty to provide reasonable and appropriate medical care and treatment within the applicable
`
`standard of care.
`
`11. Defendant, DR. FIGUEREDO, breached that duty of care by, including, but not limited to :
`
`a. Failing to apply proper surgical technique,
`
`b. Failing to adequately and timely respond to development of post-operative
`
`complications,
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 4
`
`

`

`c. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`12. As a direct and proximate result of Defendant, DR. FIGUEREDO's, negligence, Plaintiff,
`
`SHERON JOHNSON, suffered bodily injury and resulting pain and suffering, disability,
`
`disfigurement, mental anguish, loss of capacity for the enjoyment of life, expense of
`
`hospitalization, medical and nursing care and treatment, loss ofeamings, loss of ability to earn
`
`money and/or aggravation of a previously existing condition. The losses are either permanent
`
`or continuing and Plaintiff; SHERON JOHNSON, will suffer the losses in the future.
`
`13. Defendant, DR. FIGUEREDO, has failed to comply with the conditions precedent as
`
`promulgated by chapter 766, Florida Statutes, by failing to respond to Plaintiffs presuit
`
`Notice of Intent to Initiate Litigation in any way.
`
`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant, DR.
`
`FIGUEREDO, for damages in an amount in excess of $30,000.00, together with costs incurred and
`
`attorney's fees if applicable herein, and further demands a trial by jury on all issues so triable.
`
`COUNT II -. MEDICAL NEGLIGENCE as to Defendant, DR. LURIA
`
`14. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`15. On or about February 23, 2021, Plaintiff, SHERON JOHNSON, underwent cosmetic breast
`
`surgery performed by Defendant, DR. LURIA, at Co-Defendants, SMART SHAPE BODY
`
`and SMART SHAPE's, facility located at 5352 North Habana Avenue, Suite C-D in Tampa,
`
`Florida.
`
`16. At all material times, Defendant, DR. LURIA, owed Plaintiff, SHERON JOHNSON, a duty
`
`to provide reasonable and appropriate medical care and treatment within the applicable
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 5
`
`

`

`standard of care.
`
`17. Defendant, DR. LURIA, breached that duty of care by, including, but not limited to:
`
`a. Failing to apply proper surgical technique,
`
`b. Failing to adequately and timely respond to development of post-operative
`
`complications,
`
`C. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`18. As a direct and proximate result of Defendant, DR. LURIA's, negligence, Plaintiff, SHERON
`
`JOHNSON, suffered bodily injury and resulting pain and suffering, disability, disfigurement,
`
`mental anguish, loss of capacity for the enjoyment of life, expense of hospitalization, medical
`
`and nursing care and treatment, loss of earnings, loss of ability to eam money and/or
`
`aggravation of a previously existing condition. The losses are either permanent or continuing
`
`and Plaintiff, SHERON JOHNSON, will suffer the losses in the future.
`
`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant, DR.
`
`LURIA, for damages in an amount in excess of $30,000.00, together with costs incurred and
`
`attorney's fees if applicable herein, and further demands a trial by jury on all issues so triable.
`
`COUNT III - VICARIOUS LIABILITY for MEDICAL NEGLIGENCE
`as to Defendant, SMART SHAPE BODY
`
`19. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`20. On or about Febnualy 23, 2021, Plaintiff, SHERON JOHNSON, presented to Defendant,
`
`SMART SHAPE BODY's, facility located at 5352 North Habana Avenue, Suite C-D in
`
`Tampa, Florida to undergo liposuction and cosmetic breast surgery performed by Co-
`
`Defendants, DR. FIGUEREDO and DR. LURIA, respectively.
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 6
`
`

`

`21. Upon information and belief, at all material times, Co-Defendants, DR. FIGUEREDO and
`
`DR. LURIA, were employees andjor agents of Defendant, SMART SHAPE BODY, and were
`
`acting within the course and scope of their employment and/or agency with Defendant,
`
`SMART SHAPE BODY, during their care and treatment of Plaintiff SHERON JOHNSON.
`
`22. At all material times, Defendant, SMART SHAPE BODY, by and through its employees
`
`and/or agents, including, but not limited to, Co-Defendants, DR. FIGUEREDO and DR.
`
`LURIA, owed Plaintiff, SHERON JOHNSON, a duty to provide reasonable and appropriate
`
`medical care and treatment within the applicable standard of care.
`
`23. Defendant, SMART SHAPE BODY, by and through its employees and/or agents, including,
`
`but not limited to, Co-Defendants, DR. FIGUEREDO and DR. LURIA, breached that duty of
`
`care by, including, but not limited to :
`
`a. Failing to apply proper surgical technique;
`
`b. Failing to adequately and timely respond to development of post-operative
`
`complications,
`
`c. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`24. As a direct and proximate result of Co-Defendants, DR. FIGUEREDO's and DR.
`
`LURIA's, negligence, Plaintiff, SHERON JOHNSON, suffered bodily injury and resulting
`
`pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the
`
`enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of
`
`earnings, loss of ability to eam money and/or aggravation of a previously e)dsting condition.
`
`The losses are either permanent or continuing and Plaintiff, SHERON JOHNSON, will suffer
`
`the losses in the future.
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 7
`
`

`

`25. Defendant, SMART SHAPE BODY, is vicariously liable for the negligence of Co-
`
`Defendants, DR. FIGUEREDO and DR. LURIA, as described in the preceding paragraphs.
`
`26. Defendant, SMART SHAPE BODY, has failed to comply with the conditions precedent as
`
`promulgated by chapter 766, Florida Statutes, by failing to respond to Plaintiffs presuit
`
`Notice of Intent to Initiate Litigation in any way.
`
`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant,
`
`SMART SHAPE BODY, for damages in an amount in excess of $30,000.00, together with costs
`
`incurred and attorney's fees if applicable herein, and further demands a trial by jury on all issues so
`
`triable.
`
`COUNT IV - APPARENT AGENCY as to Defendant, SMART SHAPE BODY
`
`27. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`28. On or about January 12, 2021, Plaintiff; SHERON JOHNSON, presented to Defendant,
`
`SMART SHAPE BODY's, facility located at 5352 North Habana Avenue, Suite C-D in
`
`Tampa, Florida to undergo liposuction and cosmetic breast surgery performed by Co-
`
`Defendants, DR. FIGUEREDO and DR. LURIA, respectively.
`
`29. At all material times, Co-Defendants, DR. FIGUEREDO and DR. LURIA, owed Plaintiff,
`
`SHERON JOHNSON, a duty to provide reasonable and appropriate medical care and
`
`treatment within the applicable standard of care .
`
`30. Co-Defendants, DR. FIGUEREDO and DR. LURIA, breached that duty of care by, including,
`
`but not limited to:
`
`a. Failing to apply proper surgical technique,
`
`b. Failing to adequately and timely respond to development of post-operative
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 8
`
`

`

`complications,
`
`C. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`31. As a direct and proximate result of Co-Defendants, DR. FIGUEREDO's and DR.
`
`LURlA's, negligence, Plaintiff, SHERON JOHNSON, suffered bodily injury and resulting
`
`pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the
`
`enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of
`
`earnings, loss of ability to earn money and/or aggravation of a previously existing condition.
`
`The losses are either permanent or continuing and Plaintiff, SHERON JOHNSON, will suffer
`
`the losses in the future.
`
`32. At the time that Co-Defendants, DR. FIGUEREDO and DR. LURIA, undertook to provide
`
`medical care and treatment to Plaintiff; SHERON JOHNSON, Ms. Johnson was given no
`
`choice in who would be providing her surgical and post-operative services.
`
`33. At all material times, Defendant, SMART SHAPE BODY, held itself out and made
`
`representations that they have sufficient surgical and post-operative services and are equipped
`
`with appropriate facilities, physicians, nurses, and staff within their facility to handle care of
`
`patients such as Plaintiff, SHERON JOHNSON.
`
`34. Defendant, SMART SHAPE BODY, created the appearance and made representations that
`
`Co-Defendants, DR. FIGUEREDO and DR. LURIA, were its agents.
`
`35. Plaintiff, SHERON JOHNSON, did not attempt to secure a surgeon on her own, but merely
`
`accepted care and treatment from those surgeons provided to her by Defendant, SMART
`
`SHAPE BODY, specifically, Co-Defendants, DR. FIGUEREDO and DR. LURIA.
`
`36. Plaintiff, SHERON JOHNSON, relied on Defendant, SMART SHAPE BODY's,
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 9
`
`

`

`representations and reasonably accepted care and treatment from Co-Defendants, DR.
`
`FIGUEREDO and DR. LURIA, resulting in significant injury as described above.
`
`37. Defendant, SMART SHAPE BODY, is vicariously liable for the negligence of Co-
`
`Defendants, DR. FIGUEREDO and DR. LURIA, its apparent agents, as described above.
`
`38. Defendant, SMART SHAPE BODY, has failed to comply with the conditions precedent as
`
`promulgated by chapter 766, Florida Statutes, by failing to respond to Plaintiffs presuit
`
`Notice of Intent to Initiate Litigation in any way.
`
`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant,
`
`SMART SHAPE BODY, for damages in an amount in excess of $30,000.00, together with costs
`
`incurred and attorney's fees if applicable herein, and further demands a trial by jury on all issues so
`
`triable.
`
`COUNT V -. VICARIOUS LIABILITY for MEDICAL NEGLIGENCE
`as to Defendant, SMART SHAPE
`
`39. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`40. On or about February 23, 2021, Plaintiff, SHERON JOHNSON, presented to Defendant,
`
`SMART SHAPE's, facility located at 5352 North Habana Avenue, Suite C-D in Tampa,
`
`Florida to undergo liposuction and cosmetic breast surgery performed by Co-Defendants, DR.
`
`FIGUEREDO and DR. LURIA, respectively.
`
`41. Upon information and belief at all material times, Co-Defendants, DR. FIGUEREDO and
`
`DR. LURIA, were employees and/or agents of Defendant, SMART SHAPE, and were acting
`
`within the course and scope of their employment and/or agency with Defendant, SMART
`
`SHAPE, during their care and treatment of Plaintiff, SHERON JOHNSON.
`
`42. At all material times, Defendant, SMART SHAPE, by and through its employees and/or
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 10
`
`

`

`agents, including, but not limited to, Co-Defendants, DR. FIGUEREDO and DR. LURIA,
`
`owed Plaintiff; SHERON JOHNSON, a duty to provide reasonable and appropriate medical
`
`care and treatment within the applicable standard of care.
`
`43. Defendant, SMART SHAPE, by and through its employees and/or agents, including, but not
`
`limited to, Co-Defendants, DR. FIGUEREDO and DR. LURIA, breached that duty of care
`
`by, including, but not limited to:
`
`d. Failing to apply proper surgical teclmique,
`
`e. Failing to adequately and timely respond to development of post-operative
`
`complications,
`
`f. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`44. As a direct and proximate result of Co-Defendants, DR. FIGUEREDO's and DR.
`
`LURIA's, negligence, Plaintiff, SHERON JOHNSON, suffered bodily injury and resulting
`
`pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the
`
`enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of
`
`earnings, loss of ability to eam money and/or aggravation of a previously e)dsting condition.
`
`The losses are either permanent or continuing and Plaintiff, SHERON JOHNSON, will suffer
`
`the losses in the future.
`
`45. Defendant, SMART SHAPE, is vicariously liable for the negligence of Co-Defendants, DR.
`
`FIGUEREDO and DR. LURIA, as described in the preceding paragraphs.
`
`46. Defendant, SMART SHAPE, has failed to comply with the conditions precedent as
`
`promulgated by chapter 766, Florida Statutes, by failing to respond to Plaintiffs presuit
`
`Notice of Intent to Initiate Litigation in any way.
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 11
`
`

`

`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant,
`
`SMART SHAPE, for damages in an amount in excess of $30,000.00, together with costs incurred
`
`and attorney's fees if applicable herein, and further demands a trial by jury on all issues so triable.
`
`QOUNT [I - APPARENT AGENCY as to Defendant, SMART SHAPE
`
`47. Plaintiff adopts and re-alleges the allegations contained in Paragraphs 1-7 above as if fully set
`
`forth herein.
`
`48. On or about January 12, 2021, Plaintiff; SHERON JOHNSON, presented to Defendant,
`
`SMART SHAPE's, facility located at 5352 North Habana Avenue, Suite C-D in Tampa,
`
`Florida to undergo liposuction and cosmetic breast surgery performed by Co-Defendants, DR.
`
`FIGUEREDO and DR. LURIA, respectively.
`
`49. At all material times, Co-Defendants, DR. FIGUEREDO and DR. LURIA, owed Plaintiff,
`
`SHERON JOHNSON, a duty to provide reasonable and appropriate medical care and
`
`treatment within the applicable standard of care.
`
`50. Co-Defendants, DR. FIGUEREDO and DR. LURIA, breached that duty of care by, including,
`
`but not limited to :
`
`a. Failing to apply proper surgical technique,
`
`b. Failing to adequately and timely respond to development of post-operative
`
`complications,
`
`c. Otherwise failing to provide proper surgical and post-operative care and treatment to
`
`Ms. Johnson at all times.
`
`51. As a direct and proximate result of Co-Defendants, DR. FIGUEREDO's and DR.
`
`LURlA's, negligence, Plaintiff SHERON JOHNSON, suffered bodily injury and resulting
`
`pain and suffering, disability, disfigurement, mental anguish, loss of capacity for the
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 12
`
`

`

`enjoyment of life, expense of hospitalization, medical and nursing care and treatment, loss of
`
`earnings, loss of ability to earn money and/or aggravation of a previously existing condition.
`
`The losses are either permanent or continuing and Plaintiff, SHERON JOHNSON, will suffer
`
`the losses in the future.
`
`52. At the time that Co-Defendants, DR. FIGUEREDO and DR. LURIA, undertook to provide
`
`medical care and treatment to Plaintif£ SHERON JOHNSON, Ms. Johnson was given no
`
`choice in who would be providing her surgical and post-operative services.
`
`53. At all material times, Defendant, SMART SHAPE, held itself out and made representations
`
`that they have sufficient surgical and post-operative services and are equipped with
`
`appropriate facilities, physicians, nurses, and staff within their facility to handle care of
`
`patients such as Plaintiff, SHERON JOHNSON.
`
`54. Defendant, SMART SHAPE, created the appearance and made representations that Co-
`
`Defendants, DR. FIGUEREDO and DR. LURIA, were its agents.
`
`55. Plaintiff, SHERON JOHNSON, did not attempt to secure a surgeon on her own, but merely
`
`accepted care and treatment from those surgeons provided to her by Defendant, SMART
`
`SHAPE, specifically, Co-Defendants, DR. FIGUEREDO and DR. LURIA.
`
`56. Plaintiff, SHERON JOHNSON, relied on Defendant, SMART SHAPE's, representations and
`
`reasonably accepted care and treatment from Co-Defendants, DR. FIGUEREDO and DR.
`
`LURIA, resulting in significant injury as described above.
`
`57. Defendant, SMART SHAPE, is vicariously liable for the negligence of Co-Defendants, DR.
`
`FIGUEREDO and DR. LURIA, its apparent agents, as described above.
`
`58. Defendant, SMART SHAPE, has failed to comply with the conditions precedent as
`
`promulgated by chapter 766, Florida Statutes, by failing to respond to Plaintiffs presuit
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 13
`
`

`

`Notice of Intent to Initiate Litigation in any way.
`
`WHEREFORE, Plaintiff, SHERON JOHNSON, demands judgment against Defendant,
`
`SMART SHAPE, for damages in an amount in excess of $30,000.00, together with costs incurred
`
`and attorney's fees if applicable herein, and further demands a trial by jury on all issues so triable.
`
`Respectfully submitted this 27th day of October, 2022.
`
`PALMER LOPEZ, P.A.
`
`/s/_Joseph k. Lopez. Jr. _
`Joseph K. Lopez, Jr.
`Florida Bar No.: 106080
`Martin W. Palmer, Esquire
`Florida Bar No.: 0150347
`Cole C. Masterson
`Florida Bar No.: 1011928
`17543 Darby Lane
`Lutz, FL 33558
`Phone: (813) 506-5651
`Fax:
`(813) 506-5654
`E-mail: service@palmerlopez.com
`jklopez@,palmerlo_pez.com
`
`10/27/2022 4:34 PM Electronically Filed; Hillsborough County/13th Judicial Circuit Page 14
`
`

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