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`For purposes of this Motion only, Defendant will accept the allegations set forth in Plaintiff’s Complaint as true.
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`FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK, 03/08/2023 02:12:40 PM
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`Plaintiff’s
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`“knew
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`Plaintiff’s
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`false.”
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`Plaintiff’s
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`Plaintiff’s
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`Plaintiff’s
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`employee’s
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`. See Plaintiff’s Complaint, paragraph
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`. Further, Plaintiff’s
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`completing the additional training and receiving the upgraded certification. See Plaintiff’s
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`intiff’s Complaint, paragraph 14.
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`Based on the foregoing, Plaintiff’s claim for Fraudulent
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`he Plaintiff’s
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`ability to operate it. See Plaintiff’s C
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`A review of the Plaintiff’s Complaint shows that this claim is a mere
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`benefits. See Plaintiff’s Complaint, paragraphs 34, 35, and 36. These are exactly the type of
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`Based on the foregoing, Defendant requests that Plaintiff’s Complaint be
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