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Filing # 134934480 E-Filed 09/20/2021 04:20:04 PM
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION
ENRIQUE HERNANDEZ VERA,
Plaintiff, CASE NO.: 502021CA004483
vs.
HOME DEPOT U.S.A, INC.,
Defendant.
/
NOTICE OF INTENT TO SERVE SUBPOENA UNDER RULE 1.351 FOR
PRODUCTION OF DOCUMENT WITHOUT DEPOSITION FROM NON-PARTY
TO: ALL COUNSEL OF RECORD
NOTICE IS HEREBY GIVEN by the undersigned that after 10-days from the
date of service of this Notice, if service is by delivery, or 15-days from the date of
service, if the service is by mail., and if no objection is received from any party of the
intent to serve the attached Subpoena Duces Tecum, under Rule 1.351, for the
production of documents as noted on said Subpoena Duces Tecum, without
deposition, the undersigned shall issue Subpoena Duces Tecum addressed to the
following:
1. Treating Physician, Dr. John Cantando, 3319 State Road 7, Suite 313,
Wellington, Fl 33449
which is not a party, to produce the items listed at the time and place specified in
the subpoena. The deponent, the parties to this cause of action and all other
interested parties have the right to object to the production of said documents and
things, in which case the will not be required to surrender said documents or things
1
HAMILTON, MILLER & BIRTHISEL vie
150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131
*« FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZG? CLERK. 09/20/2021 04:20:04 PM ***CASE NO.: 502021CA004483
pending determination of said objection by the Court upon hearing. If no objection is
made, the Subpoena for the production of said documents or things in accordance
with this Notice shall be issued. The said Subpoena may give the recipient an option
to deliver or mail legible copies of the documents or things to the undersigned.
Recipients may condition the preparation of copies on the payment in advance of the
reasonable costs of preparing the copies. On receipt of same, the undersigned shall
furnish a legible copy of each item to any other party who request it upon payment of
a reasonable cost of preparing the copies.
Dated: September 20, 2021
Respectfully submitted,
/s/ Jennifer Miller Brooks
Jennifer Miller Brooks, Esq.
Florida Bar No. 124656
jmiller@hamiltonmillerlaw.com
Francesco DeMeo, Esq.
Florida Bar No. 092345
fdemeo@hamiltonmillerlaw.com
HAMILTON, MILLER & BIRTHISEL, LLP
Attorneys for Defendant
150 Southeast Second Avenue, Suite #1200
Miami, Florida 33131-2332
Telephone: (305) 379-3686
Facsimile: (305) 379-3690
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 20th day of September, 2021 the foregoing
document is being filed with the Clerk of Court using the E-filing Portal and served
on all counsel of record or pro se parties identified on the below Service List either
2
HAMILTON, MILLER & BIRTHISEL tip
150 SOUTHEAST SECOND AVENUE, SUITE 1200 “MIAMI, FLORIDA 33131
‘TELEPHONE: 305-379-3686 « FACSIMILE: 305-379-3690CASE NO.: 502021CA004483
via transmission of Notices of Electronic Filing generated by the E-filing Portal or in
some other authorized manner for those counsel or parties who are not authorized
to receive electronically via the E-filing Portal.
/s/ Jennifer Miller Brooks
Jennifer Miller, Esq.
SERVICE LIST
Jordan Kirby, Esquire
RUBENSTEIN LAW, P.A
9130 S. Dadeland Blvd, PH
Miami, FL 33156
Tel: (305) 661-6000 / Fax: (305) 670-7555
3
HAMILTON, MILLER & BIRTHISEL tip
150 SOUTHEAST SECOND AVENUE, SUITE 1200 “MIAMI, FLORIDA 33131
‘TELEPHONE: 305-379-3686 « FACSIMILE: 305-379-3690
Preview
Filing # 134934480 E-Filed 09/20/2021 04:20:04 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION ENRIQUE HERNANDEZ VERA, Plaintiff, CASE NO.: 502021CA004483 vs. HOME DEPOT U.S.A, INC., Defendant. / NOTICE OF INTENT TO SERVE SUBPOENA UNDER RULE 1.351 FOR PRODUCTION OF DOCUMENT WITHOUT DEPOSITION FROM NON-PARTY TO: ALL COUNSEL OF RECORD NOTICE IS HEREBY GIVEN by the undersigned that after 10-days from the date of service of this Notice, if service is by delivery, or 15-days from the date of service, if the service is by mail., and if no objection is received from any party of the intent to serve the attached Subpoena Duces Tecum, under Rule 1.351, for the production of documents as noted on said Subpoena Duces Tecum, without deposition, the undersigned shall issue Subpoena Duces Tecum addressed to the following: 1. Treating Physician, Dr. John Cantando, 3319 State Road 7, Suite 313, Wellington, Fl 33449 which is not a party, to produce the items listed at the time and place specified in the subpoena. The deponent, the parties to this cause of action and all other interested parties have the right to object to the production of said documents and things, in which case the will not be required to surrender said documents or things 1 HAMILTON, MILLER & BIRTHISEL vie 150 SOUTHEAST SECOND AVENUE, SUITE 1200 - MIAMI, FLORIDA 33131 *« FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZG? CLERK. 09/20/2021 04:20:04 PM ***CASE NO.: 502021CA004483 pending determination of said objection by the Court upon hearing. If no objection is made, the Subpoena for the production of said documents or things in accordance with this Notice shall be issued. The said Subpoena may give the recipient an option to deliver or mail legible copies of the documents or things to the undersigned. Recipients may condition the preparation of copies on the payment in advance of the reasonable costs of preparing the copies. On receipt of same, the undersigned shall furnish a legible copy of each item to any other party who request it upon payment of a reasonable cost of preparing the copies. Dated: September 20, 2021 Respectfully submitted, /s/ Jennifer Miller Brooks Jennifer Miller Brooks, Esq. Florida Bar No. 124656 jmiller@hamiltonmillerlaw.com Francesco DeMeo, Esq. Florida Bar No. 092345 fdemeo@hamiltonmillerlaw.com HAMILTON, MILLER & BIRTHISEL, LLP Attorneys for Defendant 150 Southeast Second Avenue, Suite #1200 Miami, Florida 33131-2332 Telephone: (305) 379-3686 Facsimile: (305) 379-3690 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 20th day of September, 2021 the foregoing document is being filed with the Clerk of Court using the E-filing Portal and served on all counsel of record or pro se parties identified on the below Service List either 2 HAMILTON, MILLER & BIRTHISEL tip 150 SOUTHEAST SECOND AVENUE, SUITE 1200 “MIAMI, FLORIDA 33131 ‘TELEPHONE: 305-379-3686 « FACSIMILE: 305-379-3690CASE NO.: 502021CA004483 via transmission of Notices of Electronic Filing generated by the E-filing Portal or in some other authorized manner for those counsel or parties who are not authorized to receive electronically via the E-filing Portal. /s/ Jennifer Miller Brooks Jennifer Miller, Esq. SERVICE LIST Jordan Kirby, Esquire RUBENSTEIN LAW, P.A 9130 S. Dadeland Blvd, PH Miami, FL 33156 Tel: (305) 661-6000 / Fax: (305) 670-7555 3 HAMILTON, MILLER & BIRTHISEL tip 150 SOUTHEAST SECOND AVENUE, SUITE 1200 “MIAMI, FLORIDA 33131 ‘TELEPHONE: 305-379-3686 « FACSIMILE: 305-379-3690