On December 14, 2018 a
Party Discovery
was filed
involving a dispute between
Elizabeth Balzarano,
and
Cameron Villa Llc,
Emilio Duboy,
Janine Beattie,
John Brogan,
Life Changes Addiction Treatment Center Of The Palm Beaches,
Lifeline Recovery Llc Dba Lifeline Recovery,
Warbird Properties Llc,
for OTHER NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 86721856 E-Filed 03/20/2019 05:25:43 PM
IN THE CIRCUIT COURT FOR THE 15"
JUDICIAL CIRCUIT IN AND FOR PALM
BEACH COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
CASENO.: 50-2018-CA-015763-XXXX-MB
ELIZARETH RAT 7ARANDO individually,
OOO, HRGLYIGUGLLy
and as Personal Representative of the Estate
of Michele L. Balzarano,
Plaintiff,
vs.
LIFELINE RECOVERY, LLC, et al.,
Defendants.
PLAINTIFF’S MOTION TO SHORTEN TIME TO RESPOND TO
INTERROGATORIES
Plaintiff, ELIZABETH BALZARANO, individually and as Personal Representative of
the Estate of Michelle L. Balzarano, in accordance with Florida Rule of Civil Procedure 1.340
(a) hereby moves the court to shorten the time for Defendants Lifeline Recovery, LLC, and
Warbird Properties, LLC, d/b/a Cameron Villa to respond to Interrogatories propounded by
Plaintiff on March 13, 2019:
Motion to Shorten Time
On March 13, 2019, Plaintiff propounded Interrogatories on Lifeline and Cameron Villa
Alunatad at At
Gucci at UL
yéiiig iMt0iMAlioA On ihe dociors and oiher medical personnel that may have
been involved in providing care and treatment to Michelle L. Balzarano (attached hereto as
Exhibit A.). This discovery may divulge information that would permit Plaintiff to pursue
additional causes of action against potentially unknown or yet to be identified individuals. As
CHEN. DAIAARCACUAAIINTY Cl CHADAND ANY FLED nainninnsa ne-oF-A2 DAA
PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yoreui2u ig UU.2u.t0 FIVEBalzarano v. Lifeline, et al.
Case No. 2018-CA-015763
the causes of action may be for wrongful death or medical malpractice, time is of the essence in
receiving fuli and detailed responses prior to the expiration of the applicable statute of
limitations. Florida Rule of Civil Procedure 1.340 (a) permits the court to shorten the time for a
litigant to answer interrogatories. Plaintiff respectfully requests that the Interrogatories
propounded on March 13, 2019, be responded to in 15 days from the date of service.
WHEREFORE, Plaintiff respectfully requests the court shorten the time for Lifeline and
Cameron Villas to answer the interrogatories making the due date March 28, 2019.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that the foregoing was filed with the Clerk of Court via the Florida
Courts E-Filing Portal and a true and correct copy was served via email this 20th day of March,
2019 upon Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire Cole Scott & Kissane,
OWeéi, 110 5.5, Gin Sireei, Suite 2700, Fi. Lauderdale, Fiorida 33301.
By: _/s/ Thomas Graham
THOMAS SCOLARO (FBN 178276)
THOMAS D. GRAHAM (FBN 89043)
LEESFIELD SCOLARO, P.A.
2350 Soult Dixié Hignway
Miami, Florida 33133
Telephone: 305-854-4900
Facsimile: 305-854-8266
leestield@leesfield.com
graham@leesfield.com
garcia@leesfield.com
Counsel for Plaintiff
Document Filed Date
March 20, 2019
Case Filing Date
December 14, 2018
Category
OTHER NEGLIGENCE
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Filing # 86721856 E-Filed 03/20/2019 05:25:43 PM IN THE CIRCUIT COURT FOR THE 15" JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA GENERAL JURISDICTION DIVISION CASENO.: 50-2018-CA-015763-XXXX-MB ELIZARETH RAT 7ARANDO individually, OOO, HRGLYIGUGLLy and as Personal Representative of the Estate of Michele L. Balzarano, Plaintiff, vs. LIFELINE RECOVERY, LLC, et al., Defendants. PLAINTIFF’S MOTION TO SHORTEN TIME TO RESPOND TO INTERROGATORIES Plaintiff, ELIZABETH BALZARANO, individually and as Personal Representative of the Estate of Michelle L. Balzarano, in accordance with Florida Rule of Civil Procedure 1.340 (a) hereby moves the court to shorten the time for Defendants Lifeline Recovery, LLC, and Warbird Properties, LLC, d/b/a Cameron Villa to respond to Interrogatories propounded by Plaintiff on March 13, 2019: Motion to Shorten Time On March 13, 2019, Plaintiff propounded Interrogatories on Lifeline and Cameron Villa Alunatad at At Gucci at UL yéiiig iMt0iMAlioA On ihe dociors and oiher medical personnel that may have been involved in providing care and treatment to Michelle L. Balzarano (attached hereto as Exhibit A.). This discovery may divulge information that would permit Plaintiff to pursue additional causes of action against potentially unknown or yet to be identified individuals. As CHEN. DAIAARCACUAAIINTY Cl CHADAND ANY FLED nainninnsa ne-oF-A2 DAA PILL. PAL BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, Yoreui2u ig UU.2u.t0 FIVEBalzarano v. Lifeline, et al. Case No. 2018-CA-015763 the causes of action may be for wrongful death or medical malpractice, time is of the essence in receiving fuli and detailed responses prior to the expiration of the applicable statute of limitations. Florida Rule of Civil Procedure 1.340 (a) permits the court to shorten the time for a litigant to answer interrogatories. Plaintiff respectfully requests that the Interrogatories propounded on March 13, 2019, be responded to in 15 days from the date of service. WHEREFORE, Plaintiff respectfully requests the court shorten the time for Lifeline and Cameron Villas to answer the interrogatories making the due date March 28, 2019. CERTIFICATE OF SERVICE I HEREBY CERTIFY that the foregoing was filed with the Clerk of Court via the Florida Courts E-Filing Portal and a true and correct copy was served via email this 20th day of March, 2019 upon Jonathan M. Midwall, Esquire, and Alyssa Tornberg, Esquire Cole Scott & Kissane, OWeéi, 110 5.5, Gin Sireei, Suite 2700, Fi. Lauderdale, Fiorida 33301. By: _/s/ Thomas Graham THOMAS SCOLARO (FBN 178276) THOMAS D. GRAHAM (FBN 89043) LEESFIELD SCOLARO, P.A. 2350 Soult Dixié Hignway Miami, Florida 33133 Telephone: 305-854-4900 Facsimile: 305-854-8266 leestield@leesfield.com graham@leesfield.com garcia@leesfield.com Counsel for Plaintiff