On October 15, 2019 a
Request for Copies (Pursuant to Rule 1.351) - TED WITHIN 10 DAYS OF DEFENDANT'S RECEIPT THEREOF
was filed
involving a dispute between
Smith, Lueretta,
and
Winn- Dixie Stores, Inc,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
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Filing # 103734513 E-Filed 02/21/2020 05:14:33 PM
IN THE CIRCUIT COURT OF THE 177!
JUDICIAL CIRCUIT IN AND FOR BROWARD
COUNTY, FLORIDA
CASE NO: CACE 19-021319
Lueretta Smith, individually,
Plaintiff,
VS.
Winn-Dixie Stores, Inc., a Florida corporation,
Defendant.
/
QUALIFIED WAIVER OF OBJECTION AND REQ T FOR COPIES TO BE
PROVIDED WITHIN 10 DAYS OF DEFENDANT'S RECEIPT THEREOF
The Plaintiff, by and through his/her undersigned counsel, pursuant to Rule 1.351,
Florida Rules of Civil Procedure, hereby qualifiedly waives objection to the Notices of
Production from Non-Party served by counsel for the Defendant, for the below listed, and
requests that said Defendant's counsel provide legible copies of each and every item furnished in
response to the subpoena referred to in the Notice of Production from Non-Party within (10)
days after said documents and items have been furnished or to notify Plaintiff of the non-party's
inability to provide such records. If Defendant refuses to abide by these terms, then Plaintiff
hereby OBJECTS to the issuance of the subject subpoena to non-party. Moreover, if the
Defendant refuses to abide by these terms, the Plaintiff would hereby object to the use thereof at
trial, and would further reserve the right to move or compel, for sanctions, or for an Order in
Limine restricting the use thereof, as to the records produced by the following:
RECORDS CUSTODIAN:
Elgut Eye Care
Chiropractic Natural Care Center
Broward Health Medical Center- Billing Department
Broward Health Medical Center — Medical Records
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/21/2020 05:14:33 PM.****Broward Health Medical Center — Radiology Department
Phoenix Emergency Medicine of Broward, LLC.
North Broward Radiologists, P.A.
POM MRI
Path Medical
Broward Foot and Ankle Specialists, P.A.
Christopher C. Roberts, D.O.
Lauderdale Urology Associates
Retina Group of Florida
Anesco Interventional Pain Institute
Domain TG Robinson, M.D.
Cosmetic and General Dentistry
Paileena Singh, M.D.
Satya P. Singh, M.D.
Paul L. Rondino. M.D.
Judi L. Schaffer, M.D.
Winston L. Alexis, M.D.
Broward Health Urgent Care
East Ocean Podiatry
South Florida ENT Allergy
Aetna Health Insurance Company
Rosenthal Family Dentistry
Broward Health North
CERTIFICATE OF SERVICE
I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at
pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on February 21, 2020.
Law Offices of Justin G. Morgan, P.A.
Weston Corporate Centre I
2500 Weston Road, Suite 211
Weston, Florida 33331
Tel: (954) 217-1016
Fax: (954) 217-1019
pleadings@justinmorganlaw.com
/s/ Susan Guller
SUSAN GULLER, ESQ.
F.B.N.: 385859
Document Filed Date
February 21, 2020
Case Filing Date
October 15, 2019
Category
Neg - Premises Liability Commercial
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Filing # 103734513 E-Filed 02/21/2020 05:14:33 PM IN THE CIRCUIT COURT OF THE 177! JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO: CACE 19-021319 Lueretta Smith, individually, Plaintiff, VS. Winn-Dixie Stores, Inc., a Florida corporation, Defendant. / QUALIFIED WAIVER OF OBJECTION AND REQ T FOR COPIES TO BE PROVIDED WITHIN 10 DAYS OF DEFENDANT'S RECEIPT THEREOF The Plaintiff, by and through his/her undersigned counsel, pursuant to Rule 1.351, Florida Rules of Civil Procedure, hereby qualifiedly waives objection to the Notices of Production from Non-Party served by counsel for the Defendant, for the below listed, and requests that said Defendant's counsel provide legible copies of each and every item furnished in response to the subpoena referred to in the Notice of Production from Non-Party within (10) days after said documents and items have been furnished or to notify Plaintiff of the non-party's inability to provide such records. If Defendant refuses to abide by these terms, then Plaintiff hereby OBJECTS to the issuance of the subject subpoena to non-party. Moreover, if the Defendant refuses to abide by these terms, the Plaintiff would hereby object to the use thereof at trial, and would further reserve the right to move or compel, for sanctions, or for an Order in Limine restricting the use thereof, as to the records produced by the following: RECORDS CUSTODIAN: Elgut Eye Care Chiropractic Natural Care Center Broward Health Medical Center- Billing Department Broward Health Medical Center — Medical Records *** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 02/21/2020 05:14:33 PM.****Broward Health Medical Center — Radiology Department Phoenix Emergency Medicine of Broward, LLC. North Broward Radiologists, P.A. POM MRI Path Medical Broward Foot and Ankle Specialists, P.A. Christopher C. Roberts, D.O. Lauderdale Urology Associates Retina Group of Florida Anesco Interventional Pain Institute Domain TG Robinson, M.D. Cosmetic and General Dentistry Paileena Singh, M.D. Satya P. Singh, M.D. Paul L. Rondino. M.D. Judi L. Schaffer, M.D. Winston L. Alexis, M.D. Broward Health Urgent Care East Ocean Podiatry South Florida ENT Allergy Aetna Health Insurance Company Rosenthal Family Dentistry Broward Health North CERTIFICATE OF SERVICE I certify that a copy hereof has been furnished via email to Paul J. Gamm, Esq., at pgamm@hinshawlaw.com and kcardenas@hinshawlaw.com on February 21, 2020. Law Offices of Justin G. Morgan, P.A. Weston Corporate Centre I 2500 Weston Road, Suite 211 Weston, Florida 33331 Tel: (954) 217-1016 Fax: (954) 217-1019 pleadings@justinmorganlaw.com /s/ Susan Guller SUSAN GULLER, ESQ. F.B.N.: 385859