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.
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Filing # 124507459 E-Filed 04/07/2021 03:44:29 PM
IN THE CIRCUIT COURT OF THE 77
JUDICIAL CIRCUIT, IN AND FOR
FLAGLER COUNTY, FLORIDA
CIVIL DIVISION
CASE NO.: 2021-CA-000023
THE ESTATE OF HARRY JOHNSON,
JR. by and through HARRIET S. JOHNSON,
Personal Representative,
Plaintiff,
v.
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),
Defendant.
/
DEFENDANT’S NOTICE OF SERVING FIRST SET OF
NURSING HOME INTERROGATORIES TO PLAINTIFF
COMES NOW, the Defendant, MF FLAGLER, LLC, by an through the undersigned
counsel, propounds this First Set of Nursing Home Interrogatories numbered 1-24, attached to
the Plaintiff, for answer, under oath, in writing, within the time and manner prescribed by the
Florida Rules of Civil Procedure 1.340.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished
via Electronic Mail to: Carl R. Wilander, Esq., Primary: carl@mrwlawgroup.com; Secondary:
f1@mrwlawgroup.com, on this 7" day of April, 2021.
Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/08/2021 02:51 PMQUINTAIROS, PRIETO, WOOD & BOYER, P.A.
Attorney(s) for Defendant
1475 Centrepark Blvd., Suite 130
West Palm Beach, FL 33401
Telephone: 561-686-1880
Facsimile: 561-686-1886
Primary Email service: jmorrison.pleadings@qpwblaw.com
Secondary Email service: rebecca.kimball@qpwblaw.com
BY: _Nicole M. Healy
JAMES B. MORRISON, ESQ.
Florida Bar No.: 313210
NICOLE M. HEALY, ESQ.
Florida Bar No.: 52606
JESSICA S. HERZIG, ESQ.
Florida Bar No.: 116403
Document Filed Date
April 07, 2021
Case Filing Date
January 15, 2021
Category
OTHER NEGLIGENCE NURSING HOME
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Filing # 124507459 E-Filed 04/07/2021 03:44:29 PM IN THE CIRCUIT COURT OF THE 77 JUDICIAL CIRCUIT, IN AND FOR FLAGLER COUNTY, FLORIDA CIVIL DIVISION CASE NO.: 2021-CA-000023 THE ESTATE OF HARRY JOHNSON, JR. by and through HARRIET S. JOHNSON, Personal Representative, Plaintiff, v. 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), Defendant. / DEFENDANT’S NOTICE OF SERVING FIRST SET OF NURSING HOME INTERROGATORIES TO PLAINTIFF COMES NOW, the Defendant, MF FLAGLER, LLC, by an through the undersigned counsel, propounds this First Set of Nursing Home Interrogatories numbered 1-24, attached to the Plaintiff, for answer, under oath, in writing, within the time and manner prescribed by the Florida Rules of Civil Procedure 1.340. CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via Electronic Mail to: Carl R. Wilander, Esq., Primary: carl@mrwlawgroup.com; Secondary: f1@mrwlawgroup.com, on this 7" day of April, 2021. Electronically Received in the Office of the Clerk of the Circuit Court - Flagler County, Florida - 04/08/2021 02:51 PMQUINTAIROS, PRIETO, WOOD & BOYER, P.A. Attorney(s) for Defendant 1475 Centrepark Blvd., Suite 130 West Palm Beach, FL 33401 Telephone: 561-686-1880 Facsimile: 561-686-1886 Primary Email service: jmorrison.pleadings@qpwblaw.com Secondary Email service: rebecca.kimball@qpwblaw.com BY: _Nicole M. Healy JAMES B. MORRISON, ESQ. Florida Bar No.: 313210 NICOLE M. HEALY, ESQ. Florida Bar No.: 52606 JESSICA S. HERZIG, ESQ. Florida Bar No.: 116403