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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/29/2013 11:02:24 AM.****
Electronically Filed 05/29/2013 11:02:22 AM ET
IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT
IN AND FOR BROWARD COUNTY, FLORIDA
MARY JOHNSTON,
Plaintiff,
vs. Case No.: CACE12019330
VLN DEVELOPMENT, LLC., a
Florida Limited Liability Company,
Defendant.
/
PLAINTIFF’S NOTICE OF OBJECTION TO SUBPOENA
Plaintiff, MARY JOHNSTON, by and through the undersigned counsel, hereby files this
Notice of Objection to the issuance of a subpoena, as follows:
1. Defendant served a Notice of Production from Non-Party and attached a
Subpoena duces tecum to the Records Custodian of City of Coral Springs, attached hereto as
Exhibit 1.
2. The subpoena seeks “the entire personnel file of James Johnston,” a non-party.
3. The subpoena is issued under color of authority of Federal HIPPA law, pursuant
Mary Johnston’s injury lawsuit.
4. Federal HIPPA law is not applicable to a request for a non-party’s personnel file.
5. In addition, the material sought is immaterial and collateral, and therefor
inadmissible.
6. For the foregoing reasons Plaintiff objects to the issuance of the subpoena
attached hereto as Exhibit J.Dated this 29" day of May, 2013.
Respectfully submitted,
/s/ Robert L. Vessel
Robert L. Vessel, Esquire
Florida Bar No.: 314536
Shyamie Dixit, Esq.
Florida Bar No.: 719684
Dixit Law Firm, P.A.
3030 N. Rocky Point Drive West, Suite 260
Tampa, FL 33607
Telephone: (813) 252-3999
Facsimile: (813) 252-3997
E-mail: sdixit@dixitlaw.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
electronic email: Anna D. Torres, Esquire, P.O. Box 21289, West Palm Beach, FL 33416-1289,
at eservice@powersmcnalis.com, atorres@powersmenalis.com,
jalexander@powersmenalis.com, Tploskunak@powersmenalis.com, this 29" day May, 2013.
/s/ Robert L. Vessel
Robert L. Vessel, Esquire
Florida Bar No.: 314536
Shyamie Dixit, Esq.
Florida Bar No.: 719684Exhibit 1IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 062012CA019330AXXXE
MARY JOHNSTON,
Plaintiff,
vs.
VLN DEVELOPMENT, LLC, a Florida
Limited Liability Company,
Defendant. /
NOTICE OF PRODUCTION FROM NON-PARTY
(MAIL-IN RECORDS ONLY)
TO: Shyamie Dixit, Jr, Esquire, respectivly: rvessel@dixitlaw.com; sdixit@dixitlaw.com,;
shyamiedixit@gmail.com; scampbell@dixitlaw.com
YOU ARE NOTIFIED that after (15) days from the date of service of this Notice, the
undersigned will apply to the Clerk of the Court for issuance of the attached Subpoenas directed to:
1. Records Custodian of
City of Coral Springs
Attention: Human Resources
9551 West Sample Road
Coral Springs, Florida 33065
who is not a party to this action, to produce the items listed at the time and place specified in the
Subpoena.
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished> ih
by email to the above addressee this 2&8 day of May, 2013.
POWERS MCNALIS TORRES TEEBAGY LUONGO
P.O, Box 21289
West Palm Beach, FL 33416-1289
(561) 588-3000 Telephone
(561) 588-3705 Facsimile
eEmail: eservice@powersmenalis.com
BY:
jar No.: 587141
12470/602IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO. 062012CA019330AXXXE
MARY JOHNSTON
Plaintiff,
vs.
VLN DEVELOPMENT, LLC, a Florida
Limited Liability Company,
Defendant. /
SUBPOENA DUCES TECUM
(Mail In Records Only)
THE STATE OF FLORIDA:
TO: Records Custodian of
City of Coral Springs
Attention: Human Resources
9551 West Sample Road
Coral Springs, Florida 33065
YOU ARE COMMANDED TO PROVIDE to THE LAW FIRM OF POWERS MCNALIS
TORRES TEEBAGY LUONGO, at Post Office Box 21289, West Palm Beach, Florida 33416-1289,
on June 14, 2013, the following:
The entire personnel file of James Johnston, DOB:06/28/1941; Social Security
No.: EEE; including any and all copies of his employment application,
driver’s license, social security card, alien card, work permit, time slips,
evaluations, written reprimands and payroll records, Your entire employment
file.
HIPAA Certificate- This certifies that this Subpoena has been issued in compliance
with the Health Insurance Portability and Accountability Act of 1996, (HIPAA),
Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this Subpoena has been issued
pursuant to Rules 1.410 and 1.351, Fla. R. Civ. P. The Party issuing this Subpoena
has made a good faith attempt to provide written notice to the Plaintifi/Patient listed
above by sending his/her attorney, a notice of the issuance of this Subpoena which
included sufficient information about the litigation to permit the Plaintiff/Patient toTaisé an objection to the court or administrative tribunal. The time for the
Plaintiff/Patient to raise an objection pursuant to Rule 1.351, Fla. R. Civ. P. has
expired and no objections were filed.
These items will be inspected and may be copied at that time. You will not be required to
surrender the original items. You may comply with this Subpoena by providing legible copies of the
items to be produced to the attorney whose name appears on this subpoena on or before the
scheduled date of production. You may condition the preparation of the copies upon the payment in
advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney
whose name appears on this subpoena and thereby eliminate your appearance at the time and
place specified above. You have the right to object to the production pursuant to this Subpoena at
any time before production by giving written notice to the attorney whose name appears on this
Subpoena, This is not a deposition. No testimony will be taken.
Please execute the attached Certificate of Authenticity and return with records.
IF YOU FAIL TO:
appear as specified; or
___XX_ fumish the records instead of appearing as provided above; or
object to this subpoena;
you may be in contempt of Court. You are subpoenaed by the attorney who name appears on this
Subpoena and unless excused from this Subpoena by the attorney or the Court, you shall respond to
this Subpoena as directed.
DATED this day of 2013.
POWERS MCNALIS TORRES TEEBAGY LUONGO
Attorney for Defendant
P.O. Box 21289
West Palm Beach, FL 33416-1289
(561) 588-3000 Telephone
(561) 588-3705 Facsimile
eEmajl: eservice@powersmenalis.com
BY:
7
[ILA V. ALEXANDER,
A SQUIRE
Foyida Bar No.: 587141
12470/603CERTIFICATE OF AUTHENTICITY
I HEREBY CERTIFY that the reproduction of health care records attached to this
certificate are, to the best of my knowledge, true and accurate copies of the patient records of,
James Johnston, DOB: 06/28/1941, Social Security No.: HEE the originals of which
are on file at
I FURTHER CERTIFY that said records were made at or near the time of the
occurrence(s) set forth within said records, or from information transmitted by a person having
knowledge of such matters; that said records were kept in the course of the regularly conducted
business; and that such records are made as a regular practice in the regular and ordinary course
of business,
I FURTHER CERTIFY that I am the person responsible for maintaining and controlling
said records, and/or the appointed designee responsible for the release of said records.
Dated this day of , 2012.
Records Custodian
STATE OF )
)SS:
COUNTY OF )
BEFORE ME, the undersigned authority, personally appeared >
who is personally known to me or who has produced as identification
and who after being duly sworn, deposes and states that the above matters are true and correct to
the best of his or her knowledge and belief.
NOTARY PUBLIC (Signature)
Printed Name of Notary
My Commission Expires:
12470IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT, IN AND FOR
BROWARD COUNTY, FLORIDA
CASE NO, 062012CA019330AXXXE
MARY JOHNSTON,
Plaintiff,
Vs.
VLN DEVELOPMENT, LLC, a Florida
Limited Liability Company,
Defendant. /
NOTICE OF CONFIDENTIAL INFORMATION WITHIN COURT FILING
Defendant, VLN Development, LLC, pursuant to Florida Rule of Judicial Administration
2.420(d)(2), hereby files this, its Notice of Confidential Information within Court Filing, and
state as follows:
The filer of a court record at the time of filing shall indicate whether any confidential
information is included within the document being filed; identify the confidentiality provision
that applies to the identified information; and identify the precise location of the confidential
information within the document being filed.
TITLE/TYPE OF DOCUMENT: Subpoena Duces Tecum
Indicate the applicable confidentiality provision(s) below from Rule 2.420(d)(1)(B),
by specifying the location within the document on the space provided:
Chapter 39 records relating to dependency matters, termination of parental rights,
guardians ad litem, child abuse, neglect, and abandonment. § 39.0132(3), Fla. Stat. (If the
document is filed within a Chapter 39 case, this form is not required).
Adoption records. § 63.162, Fla. Stat. (If the document is filed within a Chapter 63
adoption case, this form is not required).XX_ Social Security, bank account, charge, debit, and credit card numbers in court records. §
119.0714(1)@H{j), (2)(a)-(e), Fla. Stat. (Unless redaction is requested pursuant to § 119.0714(2),
this information is exempt only as of January 1, 2011).
HIV test results and patient identity within the HIV test results. § 381.004(3)(e), Fla. Stat.
Sexually transmitted diseases — test results and identity within the test results when
provided by the Department of Health or the department’s authorized representative, § 384.29,
Fla, Stat.
Birth and death certificates, including court-issued delayed birth certificates and fetal
death certificates. §§ 382.008(6), 382.025(1){a), Fla. Stat.
Identifying information in petition by minor for waiver of parental notice when seeking to
terminate pregnancy. § 390.01116, Fla. Stat. (If the document is filed within a Ch. 390 waiver of
parental notice case, this form is not required).
"___ Identifying information in clinical mental health records under the Baker Act. ~
§394.4615(7), Fla. Stat.
Records of substance abuse service providers which pertain to the identity, diagnosis, and
prognosis of and service provision to individuals who have received services from substance
abuse service providers. § 397,501(7), Fla. Stat.
Identifying information in clinical records of detained criminal defendants found
incompetent to proceed or acquitted by reason of insanity. § 916.107(8), Fla. Stat.
Estate inventories and accountings. § 733.604(1), Fla. Stat.
Victim’s address in domestic violence action on petitioner’s request. § 741.30(3)(b), Fla.
Stat,
Information identifying victims of sexual offenses, including child sexual abuse. §§
119.071(2)(h), 119.0714(1)(h), Fla. Stat.
Gestational surrogacy records. § 742.16(9), Fla. Stat.
Guardianship reports and orders appointing court monitors in guardianship cases. §§
744.1076, 744.3701, Fla. Stat.
Grand jury records. Ch. 905, Fla. Stat. (If the document is filed in a Ch. 905 grand jury
proceeding, this form is not required).
Information acquired by courts and law enforcement regarding family services for
children. § 984.06(3)(4), Fla. Stat. (If the document is filed in a Ch. 984 family services forchildren case, this form is not required).
Juvenile delinquency records. §§ 985.04(1), 985.045(2), Fla. Stat. (If the document is filed
in a Ch. 985 juvenile delinquency case, this form is not required).
Information disclosing the identity of persons subject to tuberculosis proceedings and
records of the Department of Health in suspected tuberculosis cases, §§ 392.545, 392.65, Fla.
Stat.
____ Presentence investigation reports and attached psychological or psychiatric
evaluations. Fla. R. Crim. P. 3.712; §§ 921.231(1)(i), 948.015(9), Fla. Stat
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via regular Electronic Mail this day of 2013, to Shyamie Dixit, Jr.,
Esq, The Dixit Law Firm, — sdixit@dixitlaw.com; — shyamiedixit@gmail.com;
scampbell@dixitlaw.com.
POWERS MCNALIS TORRES TEEBAGY LUONGO
P.O. Box 21289
West Palm Beach, FL 33416-1289
(561) 588-3000 Telephone
(561) 588-3705 Facsimile
@ or Defendant
By:
ILA V. ALEXANDER, ESQUIRE
da Bar No.: 587141
NATALIE NAVARRO, ESQUIRE
Florida Bar No.: 99909
12470/381
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*** FILED: BROWARD COUNTY, FL HOWARD FORMAN, CLERK 5/29/2013 11:02:24 AM.**** Electronically Filed 05/29/2013 11:02:22 AM ET IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA MARY JOHNSTON, Plaintiff, vs. Case No.: CACE12019330 VLN DEVELOPMENT, LLC., a Florida Limited Liability Company, Defendant. / PLAINTIFF’S NOTICE OF OBJECTION TO SUBPOENA Plaintiff, MARY JOHNSTON, by and through the undersigned counsel, hereby files this Notice of Objection to the issuance of a subpoena, as follows: 1. Defendant served a Notice of Production from Non-Party and attached a Subpoena duces tecum to the Records Custodian of City of Coral Springs, attached hereto as Exhibit 1. 2. The subpoena seeks “the entire personnel file of James Johnston,” a non-party. 3. The subpoena is issued under color of authority of Federal HIPPA law, pursuant Mary Johnston’s injury lawsuit. 4. Federal HIPPA law is not applicable to a request for a non-party’s personnel file. 5. In addition, the material sought is immaterial and collateral, and therefor inadmissible. 6. For the foregoing reasons Plaintiff objects to the issuance of the subpoena attached hereto as Exhibit J.Dated this 29" day of May, 2013. Respectfully submitted, /s/ Robert L. Vessel Robert L. Vessel, Esquire Florida Bar No.: 314536 Shyamie Dixit, Esq. Florida Bar No.: 719684 Dixit Law Firm, P.A. 3030 N. Rocky Point Drive West, Suite 260 Tampa, FL 33607 Telephone: (813) 252-3999 Facsimile: (813) 252-3997 E-mail: sdixit@dixitlaw.com CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by electronic email: Anna D. Torres, Esquire, P.O. Box 21289, West Palm Beach, FL 33416-1289, at eservice@powersmcnalis.com, atorres@powersmenalis.com, jalexander@powersmenalis.com, Tploskunak@powersmenalis.com, this 29" day May, 2013. /s/ Robert L. Vessel Robert L. Vessel, Esquire Florida Bar No.: 314536 Shyamie Dixit, Esq. Florida Bar No.: 719684Exhibit 1IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 062012CA019330AXXXE MARY JOHNSTON, Plaintiff, vs. VLN DEVELOPMENT, LLC, a Florida Limited Liability Company, Defendant. / NOTICE OF PRODUCTION FROM NON-PARTY (MAIL-IN RECORDS ONLY) TO: Shyamie Dixit, Jr, Esquire, respectivly: rvessel@dixitlaw.com; sdixit@dixitlaw.com,; shyamiedixit@gmail.com; scampbell@dixitlaw.com YOU ARE NOTIFIED that after (15) days from the date of service of this Notice, the undersigned will apply to the Clerk of the Court for issuance of the attached Subpoenas directed to: 1. Records Custodian of City of Coral Springs Attention: Human Resources 9551 West Sample Road Coral Springs, Florida 33065 who is not a party to this action, to produce the items listed at the time and place specified in the Subpoena. CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished> ih by email to the above addressee this 2&8 day of May, 2013. POWERS MCNALIS TORRES TEEBAGY LUONGO P.O, Box 21289 West Palm Beach, FL 33416-1289 (561) 588-3000 Telephone (561) 588-3705 Facsimile eEmail: eservice@powersmenalis.com BY: jar No.: 587141 12470/602IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO. 062012CA019330AXXXE MARY JOHNSTON Plaintiff, vs. VLN DEVELOPMENT, LLC, a Florida Limited Liability Company, Defendant. / SUBPOENA DUCES TECUM (Mail In Records Only) THE STATE OF FLORIDA: TO: Records Custodian of City of Coral Springs Attention: Human Resources 9551 West Sample Road Coral Springs, Florida 33065 YOU ARE COMMANDED TO PROVIDE to THE LAW FIRM OF POWERS MCNALIS TORRES TEEBAGY LUONGO, at Post Office Box 21289, West Palm Beach, Florida 33416-1289, on June 14, 2013, the following: The entire personnel file of James Johnston, DOB:06/28/1941; Social Security No.: EEE; including any and all copies of his employment application, driver’s license, social security card, alien card, work permit, time slips, evaluations, written reprimands and payroll records, Your entire employment file. HIPAA Certificate- This certifies that this Subpoena has been issued in compliance with the Health Insurance Portability and Accountability Act of 1996, (HIPAA), Public Law 104-901 and 45 CFR 164.512(e)(1)(ii) as this Subpoena has been issued pursuant to Rules 1.410 and 1.351, Fla. R. Civ. P. The Party issuing this Subpoena has made a good faith attempt to provide written notice to the Plaintifi/Patient listed above by sending his/her attorney, a notice of the issuance of this Subpoena which included sufficient information about the litigation to permit the Plaintiff/Patient toTaisé an objection to the court or administrative tribunal. The time for the Plaintiff/Patient to raise an objection pursuant to Rule 1.351, Fla. R. Civ. P. has expired and no objections were filed. These items will be inspected and may be copied at that time. You will not be required to surrender the original items. You may comply with this Subpoena by providing legible copies of the items to be produced to the attorney whose name appears on this subpoena on or before the scheduled date of production. You may condition the preparation of the copies upon the payment in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney whose name appears on this subpoena and thereby eliminate your appearance at the time and place specified above. You have the right to object to the production pursuant to this Subpoena at any time before production by giving written notice to the attorney whose name appears on this Subpoena, This is not a deposition. No testimony will be taken. Please execute the attached Certificate of Authenticity and return with records. IF YOU FAIL TO: appear as specified; or ___XX_ fumish the records instead of appearing as provided above; or object to this subpoena; you may be in contempt of Court. You are subpoenaed by the attorney who name appears on this Subpoena and unless excused from this Subpoena by the attorney or the Court, you shall respond to this Subpoena as directed. DATED this day of 2013. POWERS MCNALIS TORRES TEEBAGY LUONGO Attorney for Defendant P.O. Box 21289 West Palm Beach, FL 33416-1289 (561) 588-3000 Telephone (561) 588-3705 Facsimile eEmajl: eservice@powersmenalis.com BY: 7 [ILA V. ALEXANDER, A SQUIRE Foyida Bar No.: 587141 12470/603CERTIFICATE OF AUTHENTICITY I HEREBY CERTIFY that the reproduction of health care records attached to this certificate are, to the best of my knowledge, true and accurate copies of the patient records of, James Johnston, DOB: 06/28/1941, Social Security No.: HEE the originals of which are on file at I FURTHER CERTIFY that said records were made at or near the time of the occurrence(s) set forth within said records, or from information transmitted by a person having knowledge of such matters; that said records were kept in the course of the regularly conducted business; and that such records are made as a regular practice in the regular and ordinary course of business, I FURTHER CERTIFY that I am the person responsible for maintaining and controlling said records, and/or the appointed designee responsible for the release of said records. Dated this day of , 2012. Records Custodian STATE OF ) )SS: COUNTY OF ) BEFORE ME, the undersigned authority, personally appeared > who is personally known to me or who has produced as identification and who after being duly sworn, deposes and states that the above matters are true and correct to the best of his or her knowledge and belief. NOTARY PUBLIC (Signature) Printed Name of Notary My Commission Expires: 12470IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO, 062012CA019330AXXXE MARY JOHNSTON, Plaintiff, Vs. VLN DEVELOPMENT, LLC, a Florida Limited Liability Company, Defendant. / NOTICE OF CONFIDENTIAL INFORMATION WITHIN COURT FILING Defendant, VLN Development, LLC, pursuant to Florida Rule of Judicial Administration 2.420(d)(2), hereby files this, its Notice of Confidential Information within Court Filing, and state as follows: The filer of a court record at the time of filing shall indicate whether any confidential information is included within the document being filed; identify the confidentiality provision that applies to the identified information; and identify the precise location of the confidential information within the document being filed. TITLE/TYPE OF DOCUMENT: Subpoena Duces Tecum Indicate the applicable confidentiality provision(s) below from Rule 2.420(d)(1)(B), by specifying the location within the document on the space provided: Chapter 39 records relating to dependency matters, termination of parental rights, guardians ad litem, child abuse, neglect, and abandonment. § 39.0132(3), Fla. Stat. (If the document is filed within a Chapter 39 case, this form is not required). Adoption records. § 63.162, Fla. Stat. (If the document is filed within a Chapter 63 adoption case, this form is not required).XX_ Social Security, bank account, charge, debit, and credit card numbers in court records. § 119.0714(1)@H{j), (2)(a)-(e), Fla. Stat. (Unless redaction is requested pursuant to § 119.0714(2), this information is exempt only as of January 1, 2011). HIV test results and patient identity within the HIV test results. § 381.004(3)(e), Fla. Stat. Sexually transmitted diseases — test results and identity within the test results when provided by the Department of Health or the department’s authorized representative, § 384.29, Fla, Stat. Birth and death certificates, including court-issued delayed birth certificates and fetal death certificates. §§ 382.008(6), 382.025(1){a), Fla. Stat. Identifying information in petition by minor for waiver of parental notice when seeking to terminate pregnancy. § 390.01116, Fla. Stat. (If the document is filed within a Ch. 390 waiver of parental notice case, this form is not required). "___ Identifying information in clinical mental health records under the Baker Act. ~ §394.4615(7), Fla. Stat. Records of substance abuse service providers which pertain to the identity, diagnosis, and prognosis of and service provision to individuals who have received services from substance abuse service providers. § 397,501(7), Fla. Stat. Identifying information in clinical records of detained criminal defendants found incompetent to proceed or acquitted by reason of insanity. § 916.107(8), Fla. Stat. Estate inventories and accountings. § 733.604(1), Fla. Stat. Victim’s address in domestic violence action on petitioner’s request. § 741.30(3)(b), Fla. Stat, Information identifying victims of sexual offenses, including child sexual abuse. §§ 119.071(2)(h), 119.0714(1)(h), Fla. Stat. Gestational surrogacy records. § 742.16(9), Fla. Stat. Guardianship reports and orders appointing court monitors in guardianship cases. §§ 744.1076, 744.3701, Fla. Stat. Grand jury records. Ch. 905, Fla. Stat. (If the document is filed in a Ch. 905 grand jury proceeding, this form is not required). Information acquired by courts and law enforcement regarding family services for children. § 984.06(3)(4), Fla. Stat. (If the document is filed in a Ch. 984 family services forchildren case, this form is not required). Juvenile delinquency records. §§ 985.04(1), 985.045(2), Fla. Stat. (If the document is filed in a Ch. 985 juvenile delinquency case, this form is not required). Information disclosing the identity of persons subject to tuberculosis proceedings and records of the Department of Health in suspected tuberculosis cases, §§ 392.545, 392.65, Fla. Stat. ____ Presentence investigation reports and attached psychological or psychiatric evaluations. Fla. R. Crim. P. 3.712; §§ 921.231(1)(i), 948.015(9), Fla. Stat CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via regular Electronic Mail this day of 2013, to Shyamie Dixit, Jr., Esq, The Dixit Law Firm, — sdixit@dixitlaw.com; — shyamiedixit@gmail.com; scampbell@dixitlaw.com. POWERS MCNALIS TORRES TEEBAGY LUONGO P.O. Box 21289 West Palm Beach, FL 33416-1289 (561) 588-3000 Telephone (561) 588-3705 Facsimile @ or Defendant By: ILA V. ALEXANDER, ESQUIRE da Bar No.: 587141 NATALIE NAVARRO, ESQUIRE Florida Bar No.: 99909 12470/381