On January 15, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Johnson, Harriet S,
The Estate Of Harry Johnson Jr,
and
Alvarez, Norma,
Florida Facilities Llc,
Gulf Coast Health Care Holdings Llc,
Hc Navigator Llc,
Mf Flagler Llc,
Pensacola Administrative Services Llc,
Petretti, Charlene,
for OTHER NEGLIGENCE NURSING HOME
in the District Court of Flagler County.
Preview
Filing # 134585830 E-Filed 09/14/2021 04:33:02 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT
IN AND FOR FLAGLER COUNTY, STATE OF FLORIDA
CIVIL DIVISION
THE ESTATE OF HARRY JOHNSON, JR., by
and through HARRIET S. JOHNSON, Personal
Representative,
Plaintiff,
Vv.
MF FLAGLER, LLC; FLORIDA FACILITIES, CASE NO: 2021-CA-000023
LLC; PENSACOLA ADMINISTRATIVE
SERVICES, LLC; HC NAVIGATOR, LLC;
GULF COAST HEALTH CARE HOLDINGS,
LLC; NORMA ALVAREZ; and CHARLENE
PETRETTI (as to FLAGLER HEALTH AND
REHABILITATION CENTER),
Defendants.
MOTION TO WITHDRAW AS COUNSEL
COMES NOW, the undersigned attorney and the law firms of Wilkes & Associates, P.A.
and Mendes, Reins & Wilander, PLLC, and hereby move to withdraw as counsel for Plaintiff,
HARRIET S. JOHNSON, as Personal Representative of THE ESTATE OF HARRY JOHNSON,
JR., in the above-styled action for the reason that irreconcilable differences have arisen between
Plaintiff and undersigned counsel.
WHEREFORE, the undersigned respectfully requests this Court to enter an Order
granting withdrawal of undersigned and the law firms of Wilkes & Associates, P.A. and Mendes,
Reins & Wilander, PLLC as counsel for Plaintiff in the above-styled action.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 09/15/2021 11:43 AMCERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the above has been furnished via
the Florida Courts E-Filing Portal which sends a copy to:
James B. Morrison, Esq.
Nicole M. Healy, Esq.
Quintairos, Prieto, Wood & Boyer, P.A.
1475 Centrepark Blvd., Suite 130
West Palm Beach, FL 33401
imorrison.pleadings@qpwblaw.com
rebecea.kimball@gpwblaw.com
nicole. healy@qpwhblaw.com
Counsel for Defendants
Carl R. Wilander, Esq.
Mendes, Reins & Wilander, PLLC
4401 W. Kennedy Blvd., Suite 250
Tampa, FL 33609
carl@mrwlawgroup.com
crwteam@mrwlawgroup.com
fl@mrwlawgroup.com
Co-Counsel for Plaintiff
and via U.S. Mail to:
Harriet S. Johnson, 73 Rose Drive, Palm Coast, FL 32164; and P.O. Box 1075, Bunnell,
FL 32110, Plaintiff:
On this 14" day of September 2021.
isi: Dara @.
Dara A. Cooley, Esquire
FL Bar No: 89365
Wilkes & Associates, P. A.
fik/a Wilkes & McHugh, P.A.
Tampa Commons, Suite 800
One N. Dale Mabry Hwy
Tampa, FL 33609
T: (813) 873-0026 | F: (813) 286-8820
Primary: DCooley@yourcasematters.com
Secondary: TPADACStaff@yourcasematters.com
Tertiary: FL@yourcasematters.com
Attorney for Plaintiff
Preview
Filing # 134585830 E-Filed 09/14/2021 04:33:02 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, STATE OF FLORIDA CIVIL DIVISION THE ESTATE OF HARRY JOHNSON, JR., by and through HARRIET S. JOHNSON, Personal Representative, Plaintiff, Vv. MF FLAGLER, LLC; FLORIDA FACILITIES, CASE NO: 2021-CA-000023 LLC; PENSACOLA ADMINISTRATIVE SERVICES, LLC; HC NAVIGATOR, LLC; GULF COAST HEALTH CARE HOLDINGS, LLC; NORMA ALVAREZ; and CHARLENE PETRETTI (as to FLAGLER HEALTH AND REHABILITATION CENTER), Defendants. MOTION TO WITHDRAW AS COUNSEL COMES NOW, the undersigned attorney and the law firms of Wilkes & Associates, P.A. and Mendes, Reins & Wilander, PLLC, and hereby move to withdraw as counsel for Plaintiff, HARRIET S. JOHNSON, as Personal Representative of THE ESTATE OF HARRY JOHNSON, JR., in the above-styled action for the reason that irreconcilable differences have arisen between Plaintiff and undersigned counsel. WHEREFORE, the undersigned respectfully requests this Court to enter an Order granting withdrawal of undersigned and the law firms of Wilkes & Associates, P.A. and Mendes, Reins & Wilander, PLLC as counsel for Plaintiff in the above-styled action. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 09/15/2021 11:43 AMCERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the above has been furnished via the Florida Courts E-Filing Portal which sends a copy to: James B. Morrison, Esq. Nicole M. Healy, Esq. Quintairos, Prieto, Wood & Boyer, P.A. 1475 Centrepark Blvd., Suite 130 West Palm Beach, FL 33401 imorrison.pleadings@qpwblaw.com rebecea.kimball@gpwblaw.com nicole. healy@qpwhblaw.com Counsel for Defendants Carl R. Wilander, Esq. Mendes, Reins & Wilander, PLLC 4401 W. Kennedy Blvd., Suite 250 Tampa, FL 33609 carl@mrwlawgroup.com crwteam@mrwlawgroup.com fl@mrwlawgroup.com Co-Counsel for Plaintiff and via U.S. Mail to: Harriet S. Johnson, 73 Rose Drive, Palm Coast, FL 32164; and P.O. Box 1075, Bunnell, FL 32110, Plaintiff: On this 14" day of September 2021. isi: Dara @. Dara A. Cooley, Esquire FL Bar No: 89365 Wilkes & Associates, P. A. fik/a Wilkes & McHugh, P.A. Tampa Commons, Suite 800 One N. Dale Mabry Hwy Tampa, FL 33609 T: (813) 873-0026 | F: (813) 286-8820 Primary: DCooley@yourcasematters.com Secondary: TPADACStaff@yourcasematters.com Tertiary: FL@yourcasematters.com Attorney for Plaintiff