On May 28, 2021 a
Request,Application
was filed
involving a dispute between
Coney, Marilyn,
and
M Z Communications, Inc.,,
for Neg - Premises Liability Commercial
in the District Court of Broward County.
Preview
Filing# 138328246 E-Filed 1 1/10/2021 07:32:15 PM
IN THE CIRCUIT COURT OF THE
SEVENTEENTH JUDICIAL CIRCUIT, IN
AND
FOR
BROWARD
COUNTY,
FLORIDA
CASE NO- CACE 21-010690
MARILYN CONEY,
Plaintiff.
V
M Z COMMUNICATIONS, INC., a
Florida Profit Corporation,
Defendant.
i
PLAINTIFF'S REOUEST FOR COPIES OF DOCUMENTS
REGARDING DEFENDANT'S NOTICE OF PRODUCTION
FROM NON-PARTIES FILED ON OCTOBER 19, 2021
COMES NOW, Plaintiff,MARILYN CONEY ("Plaintiff'),
by and through her
undersigned counsel, and pursuant to Florida Rule of Civil Procedure 1.351(e),hereby requests
the Defendant, M Z COMMUNICATIONS, INC., to produce to Counsel for the Plaintiff,legible
copiesof all documents and/or materials (color,
where available)
received in response to the Notice
of Production from Non-Parties filed on October 19, 2021, in relation to the followingnon-party
entities via her Counsel's designatedelectronic mail service addresses on record.
1.
All Pro Medical Center Medical Records Department;
2.
David Levine, DO Medical Records Department;
3
Fashion OpticalRecords Department;
4.
Raymond O. Elliot,MD Medical Records Department;
5.
West Boca Medical Center BillingDepartment;
6.
West Boca Medical Center Medical Records Department;
1
*** FILED: BROWARD COUNTY, FL BRENDA D. FORMAN, CLERK 11/10/2021 07:32:14 PM.****
7.
West Boca Medical Center Radiology Department; and
8
Windsor Imaging Radiology Department.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy ofthe foregoinghas been furnished
to Anthony E. Torrente, Esq.,Hinshaw & Culbertson LLP, 2525 Ponce de Leon Boulevard, Fourth
Floor, Coral Gables, Florida 33134, Counsel for Defendant, using the Florida Courts E-Filing
Portal,to atorrente@hinshawlaw.com,jmiller@hinshawlaw.com, and ttracy@hinshawlaw.com,
on this 10th day ofNovember, 2021.
THE INJURY FIRM
/s/ Karl A. Forrest
Karl A. Forrest, Esq.
Florida Bar No.. 50683
Primary E-Mail Service Address:
eservice@flinjuryfi
irm.com
Secondary E-Mail Service Address:
records@flinjuryfirm.
com
TertiaryE-Mail Service Address:
karl@flinjuryfii
[rm.com
1608 East Commercial Boulevard
Fort Lauderdale, Florida 33334
Tel.: (954) 951-0000
Fax: (954) 951-1000
Counsel for Plaintiff
2
Document Filed Date
November 10, 2021
Case Filing Date
May 28, 2021
Category
Neg - Premises Liability Commercial
For full print and download access, please subscribe at https://www.trellis.law/.