I filed a AMENDED COMPLAINT adding the city and a police officer on 02/06/2018 but they have not appeared via. attorney nor answered the COMPLAINT as of this date. What shall I do?
The other people, non gov., have an attorney. I filed a PLAINTIFF’S FIRST REQUEST FOR ADMISSIONS AND INTERROGATORIES TO DEFENDANTS PERSUANT TO RULE 7.020b ACTIVATING FLORIDA RULES OF CIVIL PROCEDURE 1.280–1.380 NOW APPLY TO THIS CASE (DEFENDANTS ARE REPRESENTED BY ATTORNEY) on 02/26/2018.
Do I move for Summary Judgement at the 30 days against the non-government tow company employees and not the city & police officer?
Do I file and REQUEST FOR ADMISSIONS AND INTERROGATORIES for the city and police officer?
The COMPLAINT is quite sound and maybe it should be in the U.S. Courts and not State Court?
This MEMORANDUM OF LAW is made part of the Complaint as if fully set out in the COMPLAINT.
Statute Support
Upon a search of the state statutes non attorneys will come to the “reasonable belief”[means the actual knowledge or belief a prudent person should have without making an investigation, including any investigation of public records] that Title XL Chapter 715 is for giving instructions for the conditions to tow ANY vehicle parked on PRIVATE PROPERTY by tow company or police.
“715.07?Vehicles or vessels parked on private property; towing.—“
“(2)?The owner or lessee of real property, or any person authorized by the owner or lessee, which person may be the designated representative of the condominium association if the real property is a condominium, may cause any vehicle or vessel parked on such property without her or his permission to be removed by a person regularly engaged in the business of towing vehicles or vessels, without liability for the costs of removal, transportation, or storage or damages caused by such removal, transportation, or storage, under any of the following circumstances:” Title XL Ch.715.07 (2)