Tanya Suarez (Partner-Miami) and Michael Restrepo (Associate-Miami, FL) secured a complete dismissal of all claims in the Miami-Dade County Circuit Court on behalf of Wilson Elser’s clients, a global resort group and its resort property located in the Bahamas. This complex third-party action arose from an alleged recreational vehicle accident near the resort’s security gate. The third-party plaintiff alleged negligence claims against our clients, alleging that inadequate roadway lighting contributed to the accident.
 
Tanya and Michael engaged in extensive motion practice, submitting more than 500 pages of briefing. The team moved to dismiss plaintiff’s claims on multiple grounds, including expiration of the statute of limitations, failure to state a cause of action, and forum non conveniens. After nearly two hours of oral argument, the court granted the motion in full. The court agreed with Tanya and Michael’s arguments and found the statute of limitations issue to be dispositive, ruling that the claims were time-barred and untimely under Florida law, while also considering the Bahamian statute of limitations issues raised in the briefing. In light of this ruling, the court did not reach the remaining arguments, including forum non conveniens, which had previously been raised by the third-party plaintiffs (Florida residents), denied by the trial court, and affirmed on appeal in the original action, before our client’s involvement as a third-party defendant.