On June 21, 2017 a
Request,Application
was filed
involving a dispute between
Llerena, Roberto,
Llerena, Xiomara,
and
Andres Quintana Inc,
Learning And Growing Family Child Care,
Quintana Family Day Care Home,
for Comm Premises Liability
in the District Court of Miami-Dade County.
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Filing # 71213137 E-Filed 04/25/2018 11:48:26 AM
IN THE CIRCUIT COURT OF THE 11TH i
JUDICIAL CIRCUIT IN AND FOR MIAMI-
DADE COUNTY, FLORIDA. |
XIOMARA LLERENA and ROBERTO
LLERENA, GENERAL JURISDICTION DIVISION
Plaintiffs, Case No: 17-014926 CA (31) |
|
vs. Florida Bar No: 0008486 |
ANDRES QUINTANA INC. d/b/a |
QUINTANA FAMILY DAY CARE |
HOME a/k/a LEARNING AND
GROWING FAMILY CHILD CARE,
Defendant.
PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION
COME NOW the Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by and
through undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure and
requests the Defendant, ANDRES QUINTANA INC, d/b/a QUINTANA FAMILY DAY CARE
HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE,, to produce the following
for inspection and/or copying within the time prescribed by said Rule at the below-named
offices:
1. Any and all witness statements from any witnesses regarding the subject incident.
As grounds for the foregoing Request, the Plaintiff is unable without undue hardship, to
obtain the substantial equivalent of same by other means.CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed
this Rbay of April, 2018 to Luks, Santaniello, Petrillo & Jones, Heather M. Calhoon, Esq., 150
West Flagler Street, Suite 2750, Miami, FI 33130; 305-377-8900;
Healhoon@insurancedefense.net; ccarrero@insurancedefense.net
FRIEDLAND LAW GROUP
Attorneys for Plaintiff
1430 South Dixie Highway, Suite 305
Coral Gables, Florida 33146
Tel: (305) 661-2008
Fax: (305) 661-2001
By: A < a
Jonathan R. Friedland, Esq.
Document Filed Date
April 25, 2018
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 71213137 E-Filed 04/25/2018 11:48:26 AM IN THE CIRCUIT COURT OF THE 11TH i JUDICIAL CIRCUIT IN AND FOR MIAMI- DADE COUNTY, FLORIDA. | XIOMARA LLERENA and ROBERTO LLERENA, GENERAL JURISDICTION DIVISION Plaintiffs, Case No: 17-014926 CA (31) | | vs. Florida Bar No: 0008486 | ANDRES QUINTANA INC. d/b/a | QUINTANA FAMILY DAY CARE | HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE, Defendant. PLAINTIFF’S SUPPLEMENTAL REQUEST FOR PRODUCTION COME NOW the Plaintiffs, XIOMARA LLERENA and ROBERTO LLERENA, by and through undersigned counsel and pursuant to the applicable Florida Rules of Civil Procedure and requests the Defendant, ANDRES QUINTANA INC, d/b/a QUINTANA FAMILY DAY CARE HOME a/k/a LEARNING AND GROWING FAMILY CHILD CARE,, to produce the following for inspection and/or copying within the time prescribed by said Rule at the below-named offices: 1. Any and all witness statements from any witnesses regarding the subject incident. As grounds for the foregoing Request, the Plaintiff is unable without undue hardship, to obtain the substantial equivalent of same by other means.CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above and foregoing was mailed this Rbay of April, 2018 to Luks, Santaniello, Petrillo & Jones, Heather M. Calhoon, Esq., 150 West Flagler Street, Suite 2750, Miami, FI 33130; 305-377-8900; Healhoon@insurancedefense.net; ccarrero@insurancedefense.net FRIEDLAND LAW GROUP Attorneys for Plaintiff 1430 South Dixie Highway, Suite 305 Coral Gables, Florida 33146 Tel: (305) 661-2008 Fax: (305) 661-2001 By: A < a Jonathan R. Friedland, Esq.