Motion to Compel - Due Date: Complete Date: - CEDA HEALTH OF DOWNTOWN LITTLE HAVANA VS STATE FARM MUTUAL AUTO INS CO

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On May 22, 2014 a personal injury protection ($8,001 - $15,000) case was filed by Ceda Health Of Downtown Little Havana, represented by Landau Esq., Todd Andrew, against State Farm Mutual Auto Ins Co, represented by Brooks, Jonathan S, and Bueno, Sergio A, in the jurisdiction of Miami-Dade County. Judge Caryn Canner Schwartz presiding.

                        
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                          Filing # 23271907 E-Filed 02/02/2015 05:35:17 PM

0078734
IN THE COUNTY COURT IN AND
FOR MIAMI-DADE COUNTY, FLORIDA

CASE NO.: 2014-7750 CC 23
Florida Bar No.: 0015978
CEDA HEALTH OF DOWNTOWNILITTLE HAVANA, LLC A/A/O MARISOL BARRETO
PLAINTIFF(S),
VS,
STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY

DEFENDANT(S).
/

DEFENDANT’S MOTION TO COMPEL
PLAINTIFF’S RESPONSES TO INITIAL DISCOVERY

COMES NOW the Defendant STATE FARM MUTUAL AUTOMOBILE INSURANCE
COMPANY , by and through the undersigned counsel, and hereby moves this Court to enter an
order compelling the Plaintiff, CEDA HEALTH OF DOWNTOWN/LITTLE HAVANA, LLC
A/A/O MARISOL BARRETO to respond to Initial Interrogatories, Initial Request for Production,
propounded to Plaintiff on November 11, 2014 and as grounds therefore states as follows:

L. No objection to the aforementioned discovery requests were filed nor was an
extension of time in which to respond obtained.

2. To date, the Plaintiff has failed to respond to Initial Interrogator…