No. 21-303

Vignaraj Munsami Pillay v. Public Storage Inc.

Lower Court: Florida
Docketed: 2021-08-30
Status: Denied
Type: Paid
Relisted (2)
Tags: breach-of-contract civil-procedure civil-rights corporate-liability due-process evidence exculpatory-clause motion-to-dismiss negligence property-damage standing tenant-rights
Latest Conference: 2022-01-07 (distributed 2 times)
Question Presented (from Petition)

(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//201 9, 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 #.

Question Presented (AI Summary)

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 ?

Docket Entries

2022-01-10
Rehearing DENIED.
2021-12-22
DISTRIBUTED for Conference of 1/7/2022.
2021-11-22
2021-11-01
Petition DENIED.
2021-10-13
DISTRIBUTED for Conference of 10/29/2021.
2021-09-29
Brief of respondent Public Storage Inc. in opposition filed.
2020-06-03
Petition for a writ of certiorari filed. (Response due September 29, 2021)

Attorneys

Public Storage Inc.
David Lanier LuckLewis Brisbois Bisgaard & Smith, LLP, Respondent
Vignaraj Pillay
Vignaraj Munsami Pillay — Petitioner