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Vignaraj Munsami Pillay v. Public Storage Inc.

Paid petition · Supreme Court of Florida, No. SC20-82 · judgment January 17, 2020


Certiorari denied · November 1, 2021
Pre-decision estimate: 0% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Question presented

Questions (i)- Can a motion to dismiss a complaint using citations out of context from distinguishable cases,polished and crafted , and completely unrelated to this case override the evidence, facts and the reality of the complaint ? (ii)- Can a fraudelant claim relieve a huge Corporation from gross negligence ? Paragrah # 77# (iii) -Does the exculpatory clause legitimize a Coprporaion to have a gateway to continuous burglary and vandalism within its premises ? (iv) -Does the exculpatory clause relieve a Corporation from liability for the damages caused by the structually deteriorated unit ceiling during 16 years ? (v)- Does the exculpatory clause legitimize the owners fraud ? Paragraf # 76#. (vi) -Does simply denying a cause of action relieve a Corporation from breach of contract ? As detailed in paragrafs # 67,68,and 69. (vii) -Does the exculpatory clause relieve a Corporation from breach of convenant of good faith? Paragraf # 70 # ( viii) - Does the 4th District court of appeal contradict its order of 04/23//2019, given to the Corporation ? Paragrafs # 48 to 53. (ix)- In 'analysis” by the affirmed Authors of the Fourth District Court of Appeal, they categorically affirm that the break- ins occurred between 2005 and 2012, Naturally, to make such a categorical statement they have the police reports, the video surveillance cameras and even witnesses to support their claim, can they provide them to see who the real perpetrators are ? (x) -Why has Public Storage refused to inform the Petitioner of the incidents from 2012 to 2015,since there were many of them as reported in the Hollywood police report.? (xi) - Can the exculpatory clause void the statute of limitation based on the discovery of facts, a ■ witness and a Police report with the complaint filed on 02/23/2018, perfectly within the statutory period.? Paragraf #73#. (xii)- why has public storage consistently refused to provide the video surveillance cameras which would certainly identify if the criminals were an internal or outside group. Paragraf # 33 #. 06/03/2020

Counsel of record

For petitioner
Vignaraj Munsami Pillay

For respondent
David Lanier Luck
Lewis Brisbois Bisgaard & Smith, LLP

Case

Conference history
Distributed for 2 conferences

Proceedings

  1. Jan 10 2022
    Rehearing DENIED.
  2. Dec 22 2021
    DISTRIBUTED for Conference of 1/7/2022.
  3. Nov 22 2021
  4. Nov 01 2021
    Petition DENIED.
  5. Oct 13 2021
    DISTRIBUTED for Conference of 10/29/2021.
  6. Sep 29 2021
    Brief of respondent Public Storage Inc. in opposition filed.
  7. Jun 03 2020
    Petition for a writ of certiorari filed. (Response due September 29, 2021)