On June 03, 135 a
Party Discovery
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 # 180700130 E-Filed 08/28/2023 11:48:32 PM
110106-8
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.
/
DEFENDANT’S, PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH
PORT CHARLOTTE f/k/a BAYFRONT HEALTH PORT CHARLOTTE, RESPONSE
TO PLAINTIFF’S SECOND REQUEST TO PRODUCE
Defendant, PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT
CHARLOTTE //k/a BAYFRONT HEALTH PORT CHARLOTTE, by and through the
undersigned attorneys, and pursuant to the applicable Fla. R. Civ. P., responds to Plaintiff's,
Second Request For Production dated July 27, 2023 as follows:
1 Please provide a copy of any and all electronically stored video footage taken from any and
all surveillance cameras on July 7, 2020, after the incident that is the subject to this lawsuit
depicting the recreation of the accident as described in James Gregory’s deposition taken
on January 31, 2023 on pages 58-60 (attached).
RESPONSE: None in Defendant’s possession, custody or control.
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,
fic@kubickidraper.com; fic-kd@kubickidraper.com; Lissette. Hernandez@kubickidraper.com; on
this 28" day of August, 2023.
CASE NO. 21000968CA.
/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
Shorepoint Health Port Charlotte f/k/a Bayfront
Health Port Charlotte
9132 Strada P1., Suite 400
Naples, FL 34108
Phone: (239) 552-5300
Fax: (239) 552-5399
NAPecrtpleadings@wickersmith.com
Document Filed Date
August 28, 2023
Case Filing Date
June 03, 135
Category
Other - Matters not within the Other Negligence Subcategories
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Filing # 180700130 E-Filed 08/28/2023 11:48:32 PM 110106-8 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. / DEFENDANT’S, PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT CHARLOTTE f/k/a BAYFRONT HEALTH PORT CHARLOTTE, RESPONSE TO PLAINTIFF’S SECOND REQUEST TO PRODUCE Defendant, PORT CHARLOTTE HMA, LLC d/b/a SHOREPOINT HEALTH PORT CHARLOTTE //k/a BAYFRONT HEALTH PORT CHARLOTTE, by and through the undersigned attorneys, and pursuant to the applicable Fla. R. Civ. P., responds to Plaintiff's, Second Request For Production dated July 27, 2023 as follows: 1 Please provide a copy of any and all electronically stored video footage taken from any and all surveillance cameras on July 7, 2020, after the incident that is the subject to this lawsuit depicting the recreation of the accident as described in James Gregory’s deposition taken on January 31, 2023 on pages 58-60 (attached). RESPONSE: None in Defendant’s possession, custody or control. 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, fic@kubickidraper.com; fic-kd@kubickidraper.com; Lissette. Hernandez@kubickidraper.com; on this 28" day of August, 2023. CASE NO. 21000968CA. /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 Shorepoint Health Port Charlotte f/k/a Bayfront Health Port Charlotte 9132 Strada P1., Suite 400 Naples, FL 34108 Phone: (239) 552-5300 Fax: (239) 552-5399 NAPecrtpleadings@wickersmith.com