On June 21, 2017 a
Party Notice
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 # 69236062 E-Filed 03/14/2018 10:27:23 AM
USL-24148MICP 388 /DESiias
IN THE CIRCUIT COURT OF THE
VITH JUDICIAL CIRCUIT IN AND FOR
MIAMI-DADE COUNTY, FLORIDA
CASE NOL: 17-014926 CA 01 (31)
XIOMARA LLERENA AND
ROBERTO LLERENA ,
Plaintiff(s),
v5.
QUINTANA FAMILY DAY CARE HOME
OYB/A LEARNING AND GROWING FAMILY
CHILD CARE,
Defendant(s).
/
NOTICE OF NON-PARTY PRODUCTION
YOU ARE HEREBY NOTIFIED that after 10 days from the date of service of this
notice, if service is by facsimile or delivery, or 15 days from the date of service, if service is
by email or regular U.S. mail, and if no objection is received from any party, the
undersigned will issue or apply to the Clerk of this Court for issuance of Subpoenas
directed to the Records Custodians of
Blue Cross Blue Shield of FL
4800 Deerwood Campus Pkwy.
Jacksonville, FL 32231
Blue Cross Blue Shielf of PA
c/o Florida Chief Financial Officer as RA
200 East Gaines Street
Tallahassee, FL 32399-4201
who are not parties and whose addresses are as listed on the attached Subpoenas, to
produce the items listed at the time and place specified in the attached Subpoenas.Case No: 17-014926 CA 01 G1)
Page 2
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing has been
furnished via Electronic Mail, to all counsel of record on the attached Service List, this
day of March, 2018.
LUKS, SANTANIELLO,
PETRILLO & JONES
Attorneys for Defendant
150 W. Flagler Street, Suite 2750
Miami, FL 33136
Telephone: (305) 377-8900
Facsimile: (305) 377-8901
DANIEL ]. SANTANIELLO
Florida Bar No.: 860948
HEATHER M, CALHOON
Florida Bar No.: 495573
LUKSMIA-Pleadings@LS-Law.comCase No.: 17-014926 CA 01 G1)
Page 3
Michael }. Carmona, Esq.
Friedland Law Group
1430 South Dixie Highway
Sulte 305
Coral Gables, FL 33146
email @friedlandlawgroup.com
Document Filed Date
March 14, 2018
Case Filing Date
June 21, 2017
Category
Comm Premises Liability
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Filing # 69236062 E-Filed 03/14/2018 10:27:23 AM USL-24148MICP 388 /DESiias IN THE CIRCUIT COURT OF THE VITH JUDICIAL CIRCUIT IN AND FOR MIAMI-DADE COUNTY, FLORIDA CASE NOL: 17-014926 CA 01 (31) XIOMARA LLERENA AND ROBERTO LLERENA , Plaintiff(s), v5. QUINTANA FAMILY DAY CARE HOME OYB/A LEARNING AND GROWING FAMILY CHILD CARE, Defendant(s). / NOTICE OF NON-PARTY PRODUCTION YOU ARE HEREBY NOTIFIED that after 10 days from the date of service of this notice, if service is by facsimile or delivery, or 15 days from the date of service, if service is by email or regular U.S. mail, and if no objection is received from any party, the undersigned will issue or apply to the Clerk of this Court for issuance of Subpoenas directed to the Records Custodians of Blue Cross Blue Shield of FL 4800 Deerwood Campus Pkwy. Jacksonville, FL 32231 Blue Cross Blue Shielf of PA c/o Florida Chief Financial Officer as RA 200 East Gaines Street Tallahassee, FL 32399-4201 who are not parties and whose addresses are as listed on the attached Subpoenas, to produce the items listed at the time and place specified in the attached Subpoenas.Case No: 17-014926 CA 01 G1) Page 2 CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail, to all counsel of record on the attached Service List, this day of March, 2018. LUKS, SANTANIELLO, PETRILLO & JONES Attorneys for Defendant 150 W. Flagler Street, Suite 2750 Miami, FL 33136 Telephone: (305) 377-8900 Facsimile: (305) 377-8901 DANIEL ]. SANTANIELLO Florida Bar No.: 860948 HEATHER M, CALHOON Florida Bar No.: 495573 LUKSMIA-Pleadings@LS-Law.comCase No.: 17-014926 CA 01 G1) Page 3 Michael }. Carmona, Esq. Friedland Law Group 1430 South Dixie Highway Sulte 305 Coral Gables, FL 33146 email @friedlandlawgroup.com