On March 25, 2021 a
Party Notice
was filed
involving a dispute between
Magnolia Tree Apartments Inc,
and
Citizens Property Insurance Corporation,
for INSURANCE CLAIM
in the District Court of Bay County.
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Filing # 140813896 E-Filed 12/22/2021 09:41:57 AM
IN THE CIRCUIT COURT OF THE 14”
JUDICIAL CIRCUIT IN AND FOR BAY
COUNTY, FLORIDA
CASE NO.: 21-000400-CA
MAGNOLIA TREE APARTMENTS, INC.,
Plaintiff,
VS.
CITIZENS PROPERTY INSURANCE
CORPORATION,
Defendant.
ee
NOTICE OF SERVING OBJECTION TO DEFENDANT’S NOTICE OF PRODUCTION
FROM NON-PARTY
NOTICE IS HEREBY GIVEN that the Plaintiff, MAGNOLIA TREE APARTMENTS,
INC., Objects to the Defendant’s Notice of Production from Non-Party dated December 16,
2021, direct to:
1. Tristate Cabinet & Millwork, LLC, 566 Baxter Rd., Ashford, AL 36312.
2. Williamson Bros. Construction, 11205 Hutchinson Blvd., Suite D, Panama City,
Florida 32407.
Plaintiff objects to the aforementioned parties as they are consulting experts; Plaintiff will
provide documents/depositions should Plaintiff choose to disclose them as experts that
Plaintiff intends to use at trial at a later date pursuant to Florida Rules of Civil Procedure
Section 1.280(5).
INSTRUCTIONS TO ATTORNEY: DO NOT ISSUE THE REQUESTED SUBPOENAS.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 22" day of December 2021, a true and correct copy
of the foregoing has been furnished via e-Portal to: J. Pace Mawhinney, Esq., at
pmawhinney@kelleykronenberg.com, Kelley Kronenberg, 6267 Old Water Oak Road, Suite
202, Tallahassee, FL 32312, Attorneys for Defendant.
GED LAWYERS, LLP
Attorneys for the Plaintiff
7171 North Federal Highway
Boca Raton, FL 33487
Telephone: (561) 995-1966
Facsimile: (561) 241-0812
Primary Email: pdlitlaw@gedlawyers.com
Secondary Email: griccio@gedlawyers.com
BY: /s/Scott M. Rosso
SCOTT M. ROSSO, ESQ.
Florida Bar No.: 505757
DAVID R. SHAHEEN, ESQ.
Florida Bar No.: 0117947
Document Filed Date
December 22, 2021
Case Filing Date
March 25, 2021
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Filing # 140813896 E-Filed 12/22/2021 09:41:57 AM IN THE CIRCUIT COURT OF THE 14” JUDICIAL CIRCUIT IN AND FOR BAY COUNTY, FLORIDA CASE NO.: 21-000400-CA MAGNOLIA TREE APARTMENTS, INC., Plaintiff, VS. CITIZENS PROPERTY INSURANCE CORPORATION, Defendant. ee NOTICE OF SERVING OBJECTION TO DEFENDANT’S NOTICE OF PRODUCTION FROM NON-PARTY NOTICE IS HEREBY GIVEN that the Plaintiff, MAGNOLIA TREE APARTMENTS, INC., Objects to the Defendant’s Notice of Production from Non-Party dated December 16, 2021, direct to: 1. Tristate Cabinet & Millwork, LLC, 566 Baxter Rd., Ashford, AL 36312. 2. Williamson Bros. Construction, 11205 Hutchinson Blvd., Suite D, Panama City, Florida 32407. Plaintiff objects to the aforementioned parties as they are consulting experts; Plaintiff will provide documents/depositions should Plaintiff choose to disclose them as experts that Plaintiff intends to use at trial at a later date pursuant to Florida Rules of Civil Procedure Section 1.280(5). INSTRUCTIONS TO ATTORNEY: DO NOT ISSUE THE REQUESTED SUBPOENAS. CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 22" day of December 2021, a true and correct copy of the foregoing has been furnished via e-Portal to: J. Pace Mawhinney, Esq., at pmawhinney@kelleykronenberg.com, Kelley Kronenberg, 6267 Old Water Oak Road, Suite 202, Tallahassee, FL 32312, Attorneys for Defendant. GED LAWYERS, LLP Attorneys for the Plaintiff 7171 North Federal Highway Boca Raton, FL 33487 Telephone: (561) 995-1966 Facsimile: (561) 241-0812 Primary Email: pdlitlaw@gedlawyers.com Secondary Email: griccio@gedlawyers.com BY: /s/Scott M. Rosso SCOTT M. ROSSO, ESQ. Florida Bar No.: 505757 DAVID R. SHAHEEN, ESQ. Florida Bar No.: 0117947