On January 15, 2021 a
Party Notice
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 # 128586200 E-Filed 06/11/2021 12:54:42 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,
vs. CASE NO: 2021-CA-000023
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 THAT CAUSE IS AT ISSUE AND
READY TO BE SET FOR TRIAL
Plaintiff, by and through the undersigned attorney, hereby notices this Honorable Court
that the above-styled case is at issue and prays for an Order setting this action for trial pursuant
to Florida Rule of Civil Procedure 1.440, and as grounds therefore states:
1. The instant action is at issue and ready to be set for trial.
2. The instant action is to be tried before a jury, is an original action and will
require an estimated seven to ten (7-10) days.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
setting this cause for jury trial.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 06/11/2021 01:57 PMCERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 11" 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:
Nicole M. Healy, Esquire
James B. Morrison, Esquire
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@qpwblaw.com
Attorney for Defendants
/s/ Carl R. Wilander
Carl R. Wilander, Esquire
Florida Bar Number: 48239
MENDES, REINS & WILANDER, PLLC
4401 W. Kennedy Blvd., Suite 250
Tampa, FL 33609
Telephone: (813) 535-5053
carl@mrwlawgroup.com
CRWteam@mrwlawgroup.com
fl@mrwlawgroup.com
Attorney for Plaintiff
Document Filed Date
June 11, 2021
Case Filing Date
January 15, 2021
Category
OTHER NEGLIGENCE NURSING HOME
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Filing # 128586200 E-Filed 06/11/2021 12:54:42 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, vs. CASE NO: 2021-CA-000023 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 THAT CAUSE IS AT ISSUE AND READY TO BE SET FOR TRIAL Plaintiff, by and through the undersigned attorney, hereby notices this Honorable Court that the above-styled case is at issue and prays for an Order setting this action for trial pursuant to Florida Rule of Civil Procedure 1.440, and as grounds therefore states: 1. The instant action is at issue and ready to be set for trial. 2. The instant action is to be tried before a jury, is an original action and will require an estimated seven to ten (7-10) days. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order setting this cause for jury trial. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 06/11/2021 01:57 PMCERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 11" 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: Nicole M. Healy, Esquire James B. Morrison, Esquire 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@qpwblaw.com Attorney for Defendants /s/ Carl R. Wilander Carl R. Wilander, Esquire Florida Bar Number: 48239 MENDES, REINS & WILANDER, PLLC 4401 W. Kennedy Blvd., Suite 250 Tampa, FL 33609 Telephone: (813) 535-5053 carl@mrwlawgroup.com CRWteam@mrwlawgroup.com fl@mrwlawgroup.com Attorney for Plaintiff