On November 09, 2020 a
Party Discovery
was filed
involving a dispute between
Williams, Johnny,
and
Bacharach, James,
for Circuit Civil 3-D
in the District Court of Franklin County.
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Filing # 129373430 E-Filed 06/23/2021 04:28:47 PM
IN THE CIRCUIT COURT, SECOND JUDICIAL CIRCUIT
IN AND FOR FRANKLIN COUNTY, FLORIDA
JOHNNY WILLIAMS, CASE NO: 20-000089-CA
Plaintiff,
vs.
JAMES BACHARACH,
Defendant. /
NOTICE OF NON-OBJECTION AND REQUEST FOR COPIES
COME NOW the Plaintiff, JOHNNY WILLIAMS, by and through the undersigned
attorney, and hereby give notice of his/her non-objection and request for copies of any and all
documents secured pursuant to Defendant’s Notice for Production of Documents and Things
Without Deposition dated June 8, 2021 from the following party:
Bay Medical Center — Medical Records
Bay Medical Center — Billing Department
Bay Medical Center — Radiology Department
Florida Department of Corrections
eYeNE
Plaintiff's’ counsel will pay Defendant for the reasonable costs associated with complying
with this Request for Copies. Counsel for the Plaintiff will not agree to pay ANY outside
medical records retrieval company for copies or services rendered to Defendant.
Additionally, Plaintiff's Counsel will agree to pay for the X- ray films in electronic format only.
CERTIFICATE OF SERVICE
T HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished,
by the Florida Courts e-filing portal, to: [Michael A. Cinquino, Esquire, Law Office of David J.
Electronically Filed Franklin Case # 20000089CAAXMX 06/23/2021 04:28:47 PMMarsh, 2630 Centennial Place, Suite B, Tallahassee, FL 32308, meinquino@geico.com,
rd
kabevans@geico.com, talscplead@geico.com] this 23 4g day of June, 2021.
William A. Kempner, II, Esquire
FBN 006564
Morgan & Morgan
313 North Monroe Street, Suite 401
Tallahassee, Florida 32301
Primary Email: BKempner@forthepeople.com
Secondary Email: SHeard@forthepeople.com
Beardinalebolten@forthepeople.com
Phone: (850) 329-6895
Fax: (850) 270-9006
Attorney for Plaintiff
Document Filed Date
June 23, 2021
Case Filing Date
November 09, 2020
Category
Circuit Civil 3-D
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Filing # 129373430 E-Filed 06/23/2021 04:28:47 PM IN THE CIRCUIT COURT, SECOND JUDICIAL CIRCUIT IN AND FOR FRANKLIN COUNTY, FLORIDA JOHNNY WILLIAMS, CASE NO: 20-000089-CA Plaintiff, vs. JAMES BACHARACH, Defendant. / NOTICE OF NON-OBJECTION AND REQUEST FOR COPIES COME NOW the Plaintiff, JOHNNY WILLIAMS, by and through the undersigned attorney, and hereby give notice of his/her non-objection and request for copies of any and all documents secured pursuant to Defendant’s Notice for Production of Documents and Things Without Deposition dated June 8, 2021 from the following party: Bay Medical Center — Medical Records Bay Medical Center — Billing Department Bay Medical Center — Radiology Department Florida Department of Corrections eYeNE Plaintiff's’ counsel will pay Defendant for the reasonable costs associated with complying with this Request for Copies. Counsel for the Plaintiff will not agree to pay ANY outside medical records retrieval company for copies or services rendered to Defendant. Additionally, Plaintiff's Counsel will agree to pay for the X- ray films in electronic format only. CERTIFICATE OF SERVICE T HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished, by the Florida Courts e-filing portal, to: [Michael A. Cinquino, Esquire, Law Office of David J. Electronically Filed Franklin Case # 20000089CAAXMX 06/23/2021 04:28:47 PMMarsh, 2630 Centennial Place, Suite B, Tallahassee, FL 32308, meinquino@geico.com, rd kabevans@geico.com, talscplead@geico.com] this 23 4g day of June, 2021. William A. Kempner, II, Esquire FBN 006564 Morgan & Morgan 313 North Monroe Street, Suite 401 Tallahassee, Florida 32301 Primary Email: BKempner@forthepeople.com Secondary Email: SHeard@forthepeople.com Beardinalebolten@forthepeople.com Phone: (850) 329-6895 Fax: (850) 270-9006 Attorney for Plaintiff