On June 02, 100 a
Motion-Secondary
was filed
involving a dispute between
Ernestina De Armas,
Mario Salvador De Armas,
and
Charlie Will Mitchell,
Geico General Insurance Company,
for AUTO NEGLIGENCE
in the District Court of Palm Beach County.
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Filing # 131614231 E-Filed 07/28/2021 05:26:09 PM
IN THE CIRCUIT COURT OF THE ISTH
JUDICIAL CIRCUIT IN AND FOR PALM BEACH
COUNTY, FLORIDA
CASE NO. 50-2020-CA-008922-XXXX-MB (AD)
ERNESTINA DE ARMAS and MARIO
SALVADOR DE ARMAS,
Plaintiffs,
vs.
CHARLIE WILL MITCHELL and GEICO
GENERAL INSURANCE COMPANY,
Defendants.
NOTICE OF DEFENDANT CHARLIE WILL MITCHELL’S OBJECTION TO
PLAINTIFFS’ NOTICE OF PRODUCTION FROM NON-PARTY
COMES NOW, Defendant, CHARLIE WILL MITCHELL, by and through the undersigned
counsel, and pursuant to Florida Rules of Civil Procedure Rule 1.351(b), hereby serves this
Objection to Plaintiffs, Notice of Production from Non-Party, dated July 23, 2021, directed to
CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS, on the grounds that the subpoena seeks
documents that are overbroad and are not reasonably calculated to lead to the discovery of
admissible evidence
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true copy of the foregoing was furnished via Electronic
Service via the Florida Courts E-filing Eportal pursuant to the Supreme Court Administrative Order
AOSC13-490 this date, September 28, 2021 to: Peter Hunt, Esq., Rubenstein Law, P.A., 9130 S.
Dadeland Blvd., PH, Miami, FL 33156, Phunt@rubensteinlaw.com;
*** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/28/2021 05:26:09 PM ***jmoiano@rubensteinlaw.com; eservice@rubensteinlaw.com; Amy L. Das, Esq., 1555 Palm Beach
Lakes Blvd. Suite 1000, West Palm Beach, FL 33401, wpbgeico@geico.com.
COONEY TRYBUS KWAVNICK PEETS
Attomeys for Defendant, Charlie Will Mitchell
1600 West Commercial Boulevard, Suite 200
Fort Lauderdale, FL 33309
Telephone: 954-568-6669
Fax: 954-568-0085
Primary: reception@ctkplaw.com
Secondary: yhall@ctkplaw.com
clewis@ctkplaw.com
ngordon@ctkplaw.com
mbrennan@ctkplaw.com
hy
“(signed by ottotncy oleetsonicaily after review!”
By:
BRUCE TRYBUS
Florida Bar No. 972983
CAROLINE LEWIS
Florida Bar No. 104775
Document Filed Date
January 15, 1985
Case Filing Date
June 02, 100
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Filing # 131614231 E-Filed 07/28/2021 05:26:09 PM IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50-2020-CA-008922-XXXX-MB (AD) ERNESTINA DE ARMAS and MARIO SALVADOR DE ARMAS, Plaintiffs, vs. CHARLIE WILL MITCHELL and GEICO GENERAL INSURANCE COMPANY, Defendants. NOTICE OF DEFENDANT CHARLIE WILL MITCHELL’S OBJECTION TO PLAINTIFFS’ NOTICE OF PRODUCTION FROM NON-PARTY COMES NOW, Defendant, CHARLIE WILL MITCHELL, by and through the undersigned counsel, and pursuant to Florida Rules of Civil Procedure Rule 1.351(b), hereby serves this Objection to Plaintiffs, Notice of Production from Non-Party, dated July 23, 2021, directed to CELLCO PARTNERSHIP D/B/A VERIZON WIRELESS, on the grounds that the subpoena seeks documents that are overbroad and are not reasonably calculated to lead to the discovery of admissible evidence CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true copy of the foregoing was furnished via Electronic Service via the Florida Courts E-filing Eportal pursuant to the Supreme Court Administrative Order AOSC13-490 this date, September 28, 2021 to: Peter Hunt, Esq., Rubenstein Law, P.A., 9130 S. Dadeland Blvd., PH, Miami, FL 33156, Phunt@rubensteinlaw.com; *** FILED: PALM BEACH COUNTY, FL JOSEPH ABRUZZO, CLERK. 07/28/2021 05:26:09 PM ***jmoiano@rubensteinlaw.com; eservice@rubensteinlaw.com; Amy L. Das, Esq., 1555 Palm Beach Lakes Blvd. Suite 1000, West Palm Beach, FL 33401, wpbgeico@geico.com. COONEY TRYBUS KWAVNICK PEETS Attomeys for Defendant, Charlie Will Mitchell 1600 West Commercial Boulevard, Suite 200 Fort Lauderdale, FL 33309 Telephone: 954-568-6669 Fax: 954-568-0085 Primary: reception@ctkplaw.com Secondary: yhall@ctkplaw.com clewis@ctkplaw.com ngordon@ctkplaw.com mbrennan@ctkplaw.com hy “(signed by ottotncy oleetsonicaily after review!” By: BRUCE TRYBUS Florida Bar No. 972983 CAROLINE LEWIS Florida Bar No. 104775