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  • JOSHUA RAY CANTRILL et al vs KRISTOPHER SCOTT FERRIS et al document preview
  • JOSHUA RAY CANTRILL et al vs KRISTOPHER SCOTT FERRIS et al document preview
  • JOSHUA RAY CANTRILL et al vs KRISTOPHER SCOTT FERRIS et al document preview
  • JOSHUA RAY CANTRILL et al vs KRISTOPHER SCOTT FERRIS et al document preview
						
                                

Preview

a W 6 IN THE CIRCUIT COURT OF THE TWELTH JUDICIAL CIRCUIT ~% Roky IN AND FOR MANATEE COUNTY FLORIDA & By, oe &p CIVIL DIVISION Le, ‘ JOSHUA RAY CANTRILL, Plaintiff, v. CASE NO.: 2013-CA-004462 KRISTOPHER SCOTT FERRIS, RACHEL M WEBER. Defendants. / MOTION FOR RECONSIDERATION The Plaintiff, Joshua Ray Cantrill, moves this Court for Reconsideration of the Court’s April 20, 2015 Order on Plaintiff's Objections to Defendant’s Morgan/Katzman and Boecher Discovery Requests and in support states the following: 1. On April 20, 2015 the Court entered an Order on Plaintiff's Objections to Defendant’s Morgan/Katzman and Boecher Discovery Requests. The Order is attached as Exhibit “A” 2. At the April 8, 2015 hearing on this issue and by written memorandum, Plaintiff's counsel explained the burdensome nature of the requested discovery. Attached as Exhibit “B” is an Affidavit of Plaintiff's counsel further detailing the specific burdens attempting to compile the ordered discovery would entail. 3. At the April 8, 2015 hearing on this issue and by written memorandum, Plaintiff's counsel explained that there was no evidence of attorney referral to the medical provider at issue, a fact that has precluded this type of discovery. Steinger, Iscoe & Greene v. GEICO, 103 So. 2d 300 (Fla. 4" DCA 2013).4. Attached as Exhibit “C” is the Plaintiffs affidavit about the commencement of his treatment with Dr. Thomas Tolli. Wherefore, the Plaintiff, Joshua Ray Cantrill, requests this Court to enter an Order Granting Plaintiff's Motion for Reconsideration and further Order that the discovery ordered in the Court’s April 20, 2015 order will not take place. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was provided by Email to Jeffrey D. Peairs, Esq., jpeairs@dglawyers.com, spayonk@dglawyers.com and Brandon RR. Scheele, Esq. _ service- bscheele@bankerlopez.com on this 2 day ei 2015. Florida Bar No: 0173990 SALTER, HEALY, LLC P. O. Box 10807 St. Petersburg, FL 33733-0807 Telephone: (727)323-5848 Service Email: servicerob@salterhealy.com Attorney for Plaintiff