On May 17, 202 a
Party Discovery
was filed
involving a dispute between
Laposa, Debra,
and
Doe, John,
Horvath, David F,
Wal-Mart Stores East Lp,
for Premises Liability - Commercial
in the District Court of Charlotte County.
Preview
Filing # 113211903 E-Filed 09/11/2020 11:02:21 AM
IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR
CHARLOTTE COUNTY, FLORIDA
CIVIL DIVISION
DEBRA LAPOSA,
Plaintiff,
-Vvs- CASE NO.: 2020-100-CA
WAL-MART STORES EAST, LP,
A Foreign Limited Partnership, and
RYAN BARBER, Store Manager
Defendant.
RE
T FOR COPIES
Plaintiff, DEBRA LAPOSA, by and through undersigned attorneys, and pursuant to Rule
1.351 (d), Florida Rules of Civil Procedure hereby waives her objection to the Notice of Production
from Non-Party served by the Defendant, WALMART STORES EAST, LP, certificate of service
07/14/2020, and does request that Defendant provides legible copies of any and all records secured
from:
1. Florida Ear and Sinus Center;
2. Ear, Nose & Throat Specialist of FL;
3. Adult & Pediatric Allergy & Asthma;
4. Buena Vista Urgent Care;
5. AdventHealth Centra Care; and
6. United HealthCare
Pursuant to Defendant's Notice of Production From Non-Party, within ten (10) days after
said documents have been furnished to Defendant and, failing that, would hereby object to the use
thereof by Defendant at trial, and would further reserve the right to move to compel, or for
sanctions, or for an order in limine restricting the use thereof.I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
E-Mail this aay of September, 2020 to: Amanda J. Ross, Esq. and Madison P. Allen, Esq.,
HENDERSON, FRANKLIN, STARNES & HOLT, P.A., 1715 Monroe Street, Fort Myers, FL
33902-0280 at amanda.ross@henlaw.com, tracey.salerno@henlaw.com
madison.allen@henlaw.com and susan.peters@henlaw.com.
Ashley Logg, Esq. d
Morgan &\Morgan, P.A.
101 Riverfront Blvd., Suite 600
Bradenton, Florida 34205
Tele: (941) 240-3220
Fax: (941) 240-3215
Primary Email: along@forthepeople.com
Secondary Email: jherring@forthepeople.com
Florida Bar #: 0010418
Attorney for Plaintiff
Document Filed Date
September 11, 2020
Case Filing Date
May 17, 202
Category
Premises Liability - Commercial
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Filing # 113211903 E-Filed 09/11/2020 11:02:21 AM IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT IN AND FOR CHARLOTTE COUNTY, FLORIDA CIVIL DIVISION DEBRA LAPOSA, Plaintiff, -Vvs- CASE NO.: 2020-100-CA WAL-MART STORES EAST, LP, A Foreign Limited Partnership, and RYAN BARBER, Store Manager Defendant. RE T FOR COPIES Plaintiff, DEBRA LAPOSA, by and through undersigned attorneys, and pursuant to Rule 1.351 (d), Florida Rules of Civil Procedure hereby waives her objection to the Notice of Production from Non-Party served by the Defendant, WALMART STORES EAST, LP, certificate of service 07/14/2020, and does request that Defendant provides legible copies of any and all records secured from: 1. Florida Ear and Sinus Center; 2. Ear, Nose & Throat Specialist of FL; 3. Adult & Pediatric Allergy & Asthma; 4. Buena Vista Urgent Care; 5. AdventHealth Centra Care; and 6. United HealthCare Pursuant to Defendant's Notice of Production From Non-Party, within ten (10) days after said documents have been furnished to Defendant and, failing that, would hereby object to the use thereof by Defendant at trial, and would further reserve the right to move to compel, or for sanctions, or for an order in limine restricting the use thereof.I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by E-Mail this aay of September, 2020 to: Amanda J. Ross, Esq. and Madison P. Allen, Esq., HENDERSON, FRANKLIN, STARNES & HOLT, P.A., 1715 Monroe Street, Fort Myers, FL 33902-0280 at amanda.ross@henlaw.com, tracey.salerno@henlaw.com madison.allen@henlaw.com and susan.peters@henlaw.com. Ashley Logg, Esq. d Morgan &\Morgan, P.A. 101 Riverfront Blvd., Suite 600 Bradenton, Florida 34205 Tele: (941) 240-3220 Fax: (941) 240-3215 Primary Email: along@forthepeople.com Secondary Email: jherring@forthepeople.com Florida Bar #: 0010418 Attorney for Plaintiff