Miami Beach Healthcare Group, Ltd. v. Robert Bruce Donoway, M.D.
The Fourth DCA reversed the denial of a motion to transfer venue, holding that all of the plaintiff's claims—including the tort claims—accrued in Miami-Dade County where the peer review process and revocation of hospital privileges occurred. Because the plaintiff offered no evidence to rebut the defendants' affidavit after the burden shifted, the case had to be transferred to the Eleventh Judicial Circuit.
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