On August 06, 2020 a
Request,Application
was filed
involving a dispute between
Powell, Tiarhonda,
and
Sullivan, Cearra,
Sullivan, Justin,
for AUTO NEGLIGENCE
in the District Court of Madison County.
Preview
Filing # 111404847 E-Filed 08/06/2020 03:12:15 PM
IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT,
IN AND FOR THE CIRCUIT CIVIL DIVISION, OF MADISON COUNTY, FLORIDA
TIARHONDA POWELL,
Plaintiff,
CASE NO: 19000089CAAXMX
vs.
JUSTIN SULLIVAN AND CEARRA
SULLIVAN,
Defendants.
/
PLAINTIFF’S NOTICE OF NON-OBJECTION AND REQUEST FOR COPIES
COMES NOW the Plaintiff, TIARHONDA POWELL, by and through her undersigned
attorneys, pursuant to Rule 1.351(e) of the Florida Rules of Civil Procedure, hereby gives notice of
her request for copies of any and all documents secured pursuant to Defendant Notice of Production
from Non-Party dated July 31, 2020, from the following parties:
Blue Cross and Blue Shield of Florida, Inc.
Brynwood Health and Rehabilitation Center
Family First Wellness Clinic, LLC.
Madison County Memorial Hospital
Plaintiff's counsel will pay Defendant for the reasonable costs associated with complying
with this Request for Copies. Counsel for the Plaintiff will not agree to pay ANY outside
medical record retrieval company, for copies or services rendered to Defendant.
Additionally, Plaintiff's counsel will agree to pay for the X-ray films in electronic format only.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
through Florida Courts E-Filing Portal and via electronic transmittal to Senovia L. Portis,
Esquire of Peter F. Nunes & Associates, 1301 Riverplace Blvd., Suite 1904, Jacksonville, FL
Electronically Filed Madison Case # 2019000089CAAXMX 08/06/2020 03:12:15 PM32207 [flor.law-jax-clc-pleadings@statefarm.com; flor.law-senoviaportis@statefarm.com] on
this 6" day of August, 2020.
/s/ Tyler B. Everett
Tyler B. Everett, Esquire
FBN 0040969
Morgan & Morgan, PA
313 North Monroe Street, Suite 401
Tallahassee, Florida 32301
Primary Email: TEverett@forthepeople.com
Secondary Email: TEllis@forthepeople.com
JHowell@forthepeople.com
Phone: (850) 329-6895
Fax: (850) 270-9006
Attorneys for Plaintiff
Document Filed Date
August 06, 2020
Case Filing Date
August 06, 2020
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Filing # 111404847 E-Filed 08/06/2020 03:12:15 PM IN THE CIRCUIT COURT OF THE THIRD JUDICIAL CIRCUIT, IN AND FOR THE CIRCUIT CIVIL DIVISION, OF MADISON COUNTY, FLORIDA TIARHONDA POWELL, Plaintiff, CASE NO: 19000089CAAXMX vs. JUSTIN SULLIVAN AND CEARRA SULLIVAN, Defendants. / PLAINTIFF’S NOTICE OF NON-OBJECTION AND REQUEST FOR COPIES COMES NOW the Plaintiff, TIARHONDA POWELL, by and through her undersigned attorneys, pursuant to Rule 1.351(e) of the Florida Rules of Civil Procedure, hereby gives notice of her request for copies of any and all documents secured pursuant to Defendant Notice of Production from Non-Party dated July 31, 2020, from the following parties: Blue Cross and Blue Shield of Florida, Inc. Brynwood Health and Rehabilitation Center Family First Wellness Clinic, LLC. Madison County Memorial Hospital Plaintiff's counsel will pay Defendant for the reasonable costs associated with complying with this Request for Copies. Counsel for the Plaintiff will not agree to pay ANY outside medical record retrieval company, for copies or services rendered to Defendant. Additionally, Plaintiff's counsel will agree to pay for the X-ray films in electronic format only. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished through Florida Courts E-Filing Portal and via electronic transmittal to Senovia L. Portis, Esquire of Peter F. Nunes & Associates, 1301 Riverplace Blvd., Suite 1904, Jacksonville, FL Electronically Filed Madison Case # 2019000089CAAXMX 08/06/2020 03:12:15 PM32207 [flor.law-jax-clc-pleadings@statefarm.com; flor.law-senoviaportis@statefarm.com] on this 6" day of August, 2020. /s/ Tyler B. Everett Tyler B. Everett, Esquire FBN 0040969 Morgan & Morgan, PA 313 North Monroe Street, Suite 401 Tallahassee, Florida 32301 Primary Email: TEverett@forthepeople.com Secondary Email: TEllis@forthepeople.com JHowell@forthepeople.com Phone: (850) 329-6895 Fax: (850) 270-9006 Attorneys for Plaintiff