in the circuit court of the twelfth judicial circuit in … · 2018. 7. 20. · and jose l....
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IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT IN AND FOR SARASOTA COUNTY, FLORIDA
CIVIL DIVISION
OFFICE OF THE ATTORNEY GENERAL, STATE OF FLORIDA, DEPARTMENT OF LEGAL AFFAIRS, Plaintiff, Case No.: 2015-CA-006676 v. GRAND INCENTIVES, INC., a Florida corporation, d/b/a COAST TO COAST GRAND GETAWAYS and d/b/a TAKE TWO NIGHTS, and JOSE L. MARTINEZ, an individual, Defendants. /
JOINT STIPULATION FOR DISMISSAL WITH PREJUDICE OF CLAIMS
AGAINST GRAND INCENTIVES, INC. AND JOSE L. MARTINEZ
Pursuant to Florida Rule of Civil Procedure 1.420(a)(2), Plaintiff, Office of
the Attorney General, State of Florida, Department of Legal Affairs, and Defendants,
Grand Incentives, Inc., d/b/a Coast to Coast Grand Getaways, d/b/a Take Two
Nights, and Jose L. Martinez (collectively “Defendants”), by and through their
respective undersigned counsel, hereby stipulate and agree to the dismissal with
prejudice of all claims against Defendants pursuant to the terms and conditions of
Filing # 48155937 E-Filed 10/27/2016 09:46:59 AM
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the settlement agreement executed by all parties as of August 24, 2016, attached
hereto as Exhibit A, (“Settlement Agreement”), with each of the parties bearing their
own attorneys’ fees and costs, and the Court retaining jurisdiction to enforce the
Settlement Agreement.
Dated: October 27, 2016
For the Plaintiff
Pamela Jo Bondi Attorney General of Florida
/s/ Robert J. Follis
Robert Justin Follis Assistant Attorney General Florida Bar No. 560200 Office of the Attorney General Department of Legal Affairs 3507 East Frontage Road, Suite 325 Tampa, Florida 33607 Phone: (813) 287-7950 Facsimile: (813) 281-5515
For the Defendants /s/ Richard W. Epstein
Richard W. Epstein Florida Bar No. 229091 200 East Broward Blvd., Suite 1800 Fort Lauderdale, FL 33301 Email: [email protected] Telephone: (954) 491-1120 Facsimile: (954) 213-0140
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-and-
Brian R. Cummings Florida Bar No. 25854 401 E. Jackson Street, Suite 1825 Tampa, FL 33602 Email: [email protected] Telephone: (813) 769-7020 Facsimile: (813) 426-8582
Attorneys for Grand Incentives, Inc. & Jose L. Martinez
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on October 27, 2016, a true and correct copy of the foregoing has been served via Court’s electronic filing system to:
Brian R. Cummings, Esq. Greenspoon Marder, P.A. SunTrust Financial Centre 401 E. Jackson Street, Suite 1825 Tampa, FL 33602 Primary E-mail: [email protected] Secondary E-mail: [email protected] Richard W. Epstein Greenspoon Marder, P.A. 200 East Broward Boulevard, Suite 1800 Fort Lauderdale, Florida 33301 Primary E-mail: [email protected] Secondary E-mail: [email protected] Counsel for Defendants.
/s/ Robert J. Follis Assistant Attorney General
EXHIBIT A
Filing # 48155937 E-Filed 10/27/2016 09:46:59 AM
