Miami Partner Tiffany Batten secured a dismissal in a disputed case involving the Defendant, a trucking service, and multiple Plaintiffs based on repeated rule and order violations. Her discovery plan and motion practice successfully established a repeated pattern of non-compliance warranting the ultimate sanction of a dismissal with prejudice.
Ms. Batten demonstrated unwavering diligence in pursuing all available remedies in response to Plaintiffs’ failure to comply with court-ordered procedures. Specifically, after the Plaintiffs repeatedly failed to appear for their compulsory medical examinations, Ms. Batten strategically filed a Motion for Fees and Costs Related to Plaintiffs’ Failure to Appear, which the Court granted. The order reserved jurisdiction to enforce this relief, further strengthening the Defendant’s position. By meticulously documenting each infraction and presenting a comprehensive record of non-compliance, Ms. Batten ensured the Court had a clear basis to impose the dismissal with prejudice.
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