On June 03, 135 a
No Value
was filed
involving a dispute between
Gonzalez, Barbara,
and
Edwards, Michael G,
Hhs Environmental Services, Llc,
for Other - Matters not within the Other Negligence Subcategories
in the District Court of Charlotte County.
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Filing # 174209043 E-Filed 05/30/2023 03:22:35 PM
110106-
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA
BARBARA GONZALEZ, CIRCUIT CIVIL DIVISION
Plaintiff, CASE NO. 21000968CA
VS.
MICHAEL G. EDWARDS, HHS
ENVIRONMENTAL SERVICES, LLC
and PORT CHARLOTTE HMA, LLC,
d/b/a BAYFRONT HEALTH PORT
CHARLOTTE,
Defendants.
/
REQUEST FOR COPIES
TO: Helen Stratigakos, Esq. Michael J. Rossi, Esq.
Stratigakos Law, P.A. Michael J. Rossi, P.A.
COMES NOW, Defendant, PORT CHARLOTTE HMA, LLC D/B/A SHOREPOINTE
HEALTH PORT CHARLOTTE F/K/A BAYFRONT HEALTH PORT CHARLOTTE, by and
through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure,
hereby requests Plaintiff, BARBARA GONZALEZ, produce the undersigned Counsel with:
1 Copies of any and all documents produced by Defendants, MICHAEL G. EDWARDS and
HHS ENVIRONMENTAL SERVICES, LLC, in response to Plaintiff's Second Request
for Production dated 9/6/2022.
Copies of any and all documents produced by Defendant, HHS ENVIRONMENTAL
SERVICES, LLC, in response to Plaintiff's First Request for Production dated 10/15/2021,
including any and all documents subsequently produced by Defendants in Defendants’
Amended Responses to Plaintiffs First Request for Production.
*** Demand is made for copies via email as PDF files. “All
documents required or permitted to be served on another party must
be served by e-mail, unless this rule otherwise provides.” Fla. R. Jud.
Admin. 2.516(b)(1). Defendants agree to pay the reasonable costs for
preparing the copies of the records upon receipt. Digital production
is preferred. ***
CASE NO. 21000968CA.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida
ePortal to: Helen Stratigakos, Esquire, helen@stratigakoslaw.com, marty@stratigakoslaw.com;
Michael J. Rossi, Esquire, michael@michaelrossilaw.com; Francesca Ippolito-Craven, Esq.,
fic@kubickidraper.com; fic-kd@kubickidraper.com; Lissette. Hernandez@kubickidraper.com; on
this 30" day of May, 2023.
/s/ Brittany A. Perez, Esq.
Julie A. Campbell, Esquire
Florida Bar No. 0050134
Brittany A. Perez, Esquire
Florida Bar No. 124467
WICKER SMITH O'HARA McCOY & FORD, P.A
Attorneys for Port Charlotte HMA, LLC d/b/a
Bayfront Health Port Charlotte
9132 Strada P1., Suite 400
Naples, FL 34108
Phone: (239) 552-5300
Fax: (239) 552-5399
NAPertpleadings@wickersmith.com
-2-
Document Filed Date
January 02, 2024
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 174209043 E-Filed 05/30/2023 03:22:35 PM 110106- IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA BARBARA GONZALEZ, CIRCUIT CIVIL DIVISION Plaintiff, CASE NO. 21000968CA VS. MICHAEL G. EDWARDS, HHS ENVIRONMENTAL SERVICES, LLC and PORT CHARLOTTE HMA, LLC, d/b/a BAYFRONT HEALTH PORT CHARLOTTE, Defendants. / REQUEST FOR COPIES TO: Helen Stratigakos, Esq. Michael J. Rossi, Esq. Stratigakos Law, P.A. Michael J. Rossi, P.A. COMES NOW, Defendant, PORT CHARLOTTE HMA, LLC D/B/A SHOREPOINTE HEALTH PORT CHARLOTTE F/K/A BAYFRONT HEALTH PORT CHARLOTTE, by and through undersigned counsel, and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby requests Plaintiff, BARBARA GONZALEZ, produce the undersigned Counsel with: 1 Copies of any and all documents produced by Defendants, MICHAEL G. EDWARDS and HHS ENVIRONMENTAL SERVICES, LLC, in response to Plaintiff's Second Request for Production dated 9/6/2022. Copies of any and all documents produced by Defendant, HHS ENVIRONMENTAL SERVICES, LLC, in response to Plaintiff's First Request for Production dated 10/15/2021, including any and all documents subsequently produced by Defendants in Defendants’ Amended Responses to Plaintiffs First Request for Production. *** Demand is made for copies via email as PDF files. “All documents required or permitted to be served on another party must be served by e-mail, unless this rule otherwise provides.” Fla. R. Jud. Admin. 2.516(b)(1). Defendants agree to pay the reasonable costs for preparing the copies of the records upon receipt. Digital production is preferred. *** CASE NO. 21000968CA. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a copy hereof has been electronically served via Florida ePortal to: Helen Stratigakos, Esquire, helen@stratigakoslaw.com, marty@stratigakoslaw.com; Michael J. Rossi, Esquire, michael@michaelrossilaw.com; Francesca Ippolito-Craven, Esq., fic@kubickidraper.com; fic-kd@kubickidraper.com; Lissette. Hernandez@kubickidraper.com; on this 30" day of May, 2023. /s/ Brittany A. Perez, Esq. Julie A. Campbell, Esquire Florida Bar No. 0050134 Brittany A. Perez, Esquire Florida Bar No. 124467 WICKER SMITH O'HARA McCOY & FORD, P.A Attorneys for Port Charlotte HMA, LLC d/b/a Bayfront Health Port Charlotte 9132 Strada P1., Suite 400 Naples, FL 34108 Phone: (239) 552-5300 Fax: (239) 552-5399 NAPertpleadings@wickersmith.com -2-