PLAINTIFF=S PROPOSAL FOR SETTLEMENT

IN THE CIRCUIT COURT OF THE 11TH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO: XXXX

JOHN SMITH,

Plaintiff,

vs.

VACATION CRUISES,

Defendant.

__________________________________/

PLAINTIFF=S PROPOSAL FOR SETTLEMENT

The Plaintiff, JOHN SMITH, serves this Proposal for Settlement to Defendant, VACATION CRUISES, as follows:

The Plaintiff, pursuant to Rule 1.442, Florida Rules of Civil Procedure, and ‘768.79, Florida Statutes, hereby demands that the Defendant, VACATION CRUISES,  pay the sum of XXXX Dollars in settlement of all of Plaintiff=s claims against Defendant, VACATION CRUISES.

There are no non-monetary terms of the settlement and none of the amount demands constitutes punitive damages.  The XXXX is inclusive of attorney=s fees and costs.  Attorney=s fees are not an element of damages in this case.

CERTIFICATE OF SERVICE

IT IS HEREBY CERTIFIED that on this ____ day of XXXX, 20__, a true and correct copy of the foregoing was mailed to: XXXX.

LAW OFFICE OF ALAN D. SACKRIN

Attorney for Plaintiff

2100 East Hallandale Beach Blvd., #200

Hallandale Beach, FL 33009

By:__________________________

ALAN D. SACKRIN

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