PEREZ, MARIO vs. MARRIOTT INTERNATIONALet al.

1.5 Defendant, SUNBELT RENTALS, is a foreign corporation who is authorized to conduct and who does conduct business in the State of Florida, who at all times material hereto was and is doing business in Florida, and who maintains a registered agent in the State of Florida.

1.6 Defendant, OSHKOSH CORPORATION d/b/a JLG INDUSTRIES, INC., is a foreign corporation who is authorized to conduct and who does conduct business in the State of Florida, who at all times material hereto was and is doing business in Florida, and who maintains a registered agent in the State of Florida.

1.7 All conditions precedent for filing and maintaining this action have been fulfilled, have been waived, or do not apply.

2.1 At all times material hereto, Plaintiff, MARIO NAVARRO PEREZ, was a resident of St. Cloud, Osceola County, Florida.

3.1 Defendant, MARRIOTT INTERNATIONAL, INC. (hereinafter "MARRIOTT"), is a foreign for-profit corporation organized and incorporated under the laws of the State of Delaware with its principal place of business in Bethesda, Maryland. MARRIOTT is licensed and registered to do business in the State of Florida and maintains a registered agent in the State of Florida, Corporation Service Company, which may be served with legal process in Leon County at .

3.2 At all material times, MARRIOTT, was engaged in the hotel, travel, and tourism business and, personally or through an agent, in the County and in the District in which this Complaint is filed, operated, conducted, engaged in or carried on a business venture in this state and/or county, and had an office or agency in this state. MARRIOTT owned the premises where the subject

incident occurred; hired Plaintiff's employer, Millenium Security Services d/b/a Millenium Waves, to perform work on said property including, but not limited to the installation of televisions and speakers in the pool area; and rented equipment designed, manufactured, and marketed by Defendant, OSHKOSH CORPORATION d/b/a JLG INDUSTRIES, INC., from Defendant, SUNBELT RENTALS, INC., including the scissor lift at issue in this action.

3.3 The Defendant, SUNBELT RENTALS, INC. (hereinafter "SUNBELT"), is a foreign for- profit corporation organized and incorporated under the laws of the State of North Carolina with its principal place of business in Fort Mill, South Carolina. SUNBELT is licensed and registered to do business in the State of Florida and maintains a registered agent in the State of Florida, CT Corporation System, which may be served with legal process in Broward County at .

3.4 At all material times, SUNBELT, was engaged in the equipment and tool rental business and, personally or through an agent, in the County and in the District in which this Complaint is filed, operated, conducted, engaged in or carried on a business venture in this state and/or county, and had an office or agency in this state. SUNBELT owned and/or maintained the equipment designed, manufactured, and marketed by Defendant, OSHKOSH CORPORATION d/b/a JLG INDUSTRIES, INC., and rented out to Defendant, MARRIOTT, including the scissor lift at issue in this action.

3.5 The Defendant, OSHKOSH CORPORATION d/b/a JLG INDUSTRIES, INC., is a foreign for-profit corporation organized and incorporated under the laws of the State of Wisconsin with its principal place of business in Oshkosh, Wisconsin¹. OSHKOSH CORPORATION is licensed