On January 15, 2021 a
Party Discovery
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 # 129549132 E-Filed 06/25/2021 04:20:01 PM
IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT
IN AND FOR FLAGLER COUNTY, STATE OF FLORIDA
CIVIL DIVISON
THE ESTATE OF HARRY JOHNSON,
JR., by and through, HARRIET S. JOHNSON,
Personal Representative,
Plaintiff,
CASE NO.: 2021-CA-000023
vs.
MF FLAGLER, LLC.; FLORIDA FACILITIES,
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.
/
PLAINTIFF’S NOTICE OF SERVING ANSWERS TO DEFENDANT’S
“FIRST SET OF NURSING HOME INTERROGAOTRIES TO P. NTIFF”
COMES NOW, Plaintiff, THE ESTATE OF HARRY JOHNSON, JR., by and through,
HARRIET S. JOHNSON, Personal Representative, by and through the undersigned attorney, and
hereby gives Plaintiff's Notice of Serving Unverified Answers to Defendant’s “First Set of Nursing
Home Interrogatories to Plaintiff’ propounded on April 7, 2021, numbered one (1) through twenty-
four (24), and states that said answers have been served to all parties herein.
[CERTIFICATE OF SERVICE ON FOLLOWING PAGE]
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 06/28/2021 02:51 PMCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 25" day of June 2021, a true and correct copy of the
foregoing has been furnished to the following counsel of record via the Florida Courts E-Filing
Portal:
James B. Morrison, Esq.
Nicole M. Healy, Esq.
Jessica S. Herzig, Esq.
Quintairos, Prieto, Wood & Boyer, P.A.
1475 Centrepark Boulevard, Suite 130
West Palm Beach, Florida 33401
Primary Email: jmorrison.pleadings@qpwblaw.com
Secondary Email: Rebecca.kimball@qpwblaw.com
Attorneys for Defendant
/s/ Carl R. Wilander
Carl R. Wilander, Esquire
Florida Bar Number: 48239
MENDES, REINS & WILANDER, PLLC
4401 W. Kennedy Blvd., Ste. 250
Tampa, FL 33609
Telephone: (813) 535-5053
carl@mrwlawgroup.com
fl@mrwlawgroup.com
Co-Counsel for Plaintiff
Document Filed Date
June 25, 2021
Case Filing Date
January 15, 2021
Category
OTHER NEGLIGENCE NURSING HOME
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Filing # 129549132 E-Filed 06/25/2021 04:20:01 PM IN THE CIRCUIT COURT OF THE SEVENTH JUDICIAL CIRCUIT IN AND FOR FLAGLER COUNTY, STATE OF FLORIDA CIVIL DIVISON THE ESTATE OF HARRY JOHNSON, JR., by and through, HARRIET S. JOHNSON, Personal Representative, Plaintiff, CASE NO.: 2021-CA-000023 vs. MF FLAGLER, LLC.; FLORIDA FACILITIES, 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. / PLAINTIFF’S NOTICE OF SERVING ANSWERS TO DEFENDANT’S “FIRST SET OF NURSING HOME INTERROGAOTRIES TO P. NTIFF” COMES NOW, Plaintiff, THE ESTATE OF HARRY JOHNSON, JR., by and through, HARRIET S. JOHNSON, Personal Representative, by and through the undersigned attorney, and hereby gives Plaintiff's Notice of Serving Unverified Answers to Defendant’s “First Set of Nursing Home Interrogatories to Plaintiff’ propounded on April 7, 2021, numbered one (1) through twenty- four (24), and states that said answers have been served to all parties herein. [CERTIFICATE OF SERVICE ON FOLLOWING PAGE] Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 06/28/2021 02:51 PMCERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 25" day of June 2021, a true and correct copy of the foregoing has been furnished to the following counsel of record via the Florida Courts E-Filing Portal: James B. Morrison, Esq. Nicole M. Healy, Esq. Jessica S. Herzig, Esq. Quintairos, Prieto, Wood & Boyer, P.A. 1475 Centrepark Boulevard, Suite 130 West Palm Beach, Florida 33401 Primary Email: jmorrison.pleadings@qpwblaw.com Secondary Email: Rebecca.kimball@qpwblaw.com Attorneys for Defendant /s/ Carl R. Wilander Carl R. Wilander, Esquire Florida Bar Number: 48239 MENDES, REINS & WILANDER, PLLC 4401 W. Kennedy Blvd., Ste. 250 Tampa, FL 33609 Telephone: (813) 535-5053 carl@mrwlawgroup.com fl@mrwlawgroup.com Co-Counsel for Plaintiff