On September 13, 2021 a
Motion-Secondary
was filed
involving a dispute between
Miranda, Ana L,
and
Geico General Insurance Company,
Moore, John,
Ward, Travis N,
for Circuit Civil
in the District Court of Lake County.
Preview
Filing # 140276509 E-Filed 12/13/2021 03:55:02 PM
IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE
COUNTY, FLORIDA
ANA L. MIRANDA, CASE NO: 35-2021-CA-001576-AXXX-XX
Plaintiff,
vs.
TRAVIS N. WARD AND GEICO
GENERAL INSURANCE COMPANY,
Defendant.
/
OBJECTION TO PRODUCTION FROM NON-PARTIES
Plaintiff, ANA L. MIRANDA, by and through the undersigned attorneys, pursuant to
Rule 1.351(b) of the Florida Rules of Civil Procedure, hereby files this Objection to Production
from Non-Party providers listed on Defendant’s Notice of Production from Non-Party dated
December 8, 2021, for the following parties:
1 CarePlus Health Plans, INC.
Corporation Service Company
1201 Hays Street.
Tallahassee, FL 32301
Davenport Medical Center
2500 Berry Blvd
Davenport, FL 33897
Plaintiff requests that no subpoena be served pursuant to Rule 1.351. As grounds for such
objection, the undersigned has had difficult experiences with other attorneys relating to
questionable practices involving Notice of Production of Non-Parties and based upon that
experience, and other similar ones, the undersigned now is caused to object to all Notices of
Production in all cases. However, the Defendant may promptly obtain the same information
without delay by utilizing Rule 1.310, by way of a records pick-up, deposition or, including
FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 12/14/2021 10:55:26 AM
Plaintiffs counsel as a party to obtain the same records being produced to Defendant on the
Subpoena Duces Tecum. Defense counsel is requested not to issue any subpoenas.
CERTIFICATE OF SERVICE
THEREBY CERTIFY that on December 3, 2021, I electronically filed the foregoing with
the Clerk of the Courts by using the Florida Courts eFiling Portal which will send notification of
electronic filing to the following: Joshua M. Parks, Esquire at the Law Office of Terryl Blackmon
Walker, 901 N. Lake Destiny Road, Suite 105 Maitland, FL 32751;
[Joshua_M_Parks@Progressive.com], and Michael J. Stewart, Esquire at the Law Office of Sarah
E. Blazak, 111 North Orange Avenue, Suite 1600, Orlando, Florida 32801 ;[mistewart@geico.com].
Eloisa Pino, Esquire
FBN: 1025065
Morgan & Morgan, P.A.
20 N. Orange Avenue
Suite 1600
Orlando, FL 32801
Telephone: (689) 219-2080
Facsimile: (689) 219-2180
Primary email: epino@forthepeople.com
Secondary email: bcarpanzano@forthepeople.com
Attorneys for Plaintiff
Document Filed Date
December 13, 2021
Case Filing Date
September 13, 2021
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Filing # 140276509 E-Filed 12/13/2021 03:55:02 PM IN THE CIRCUIT COURT OF THE FIFTH JUDICIAL CIRCUIT, IN AND FOR LAKE COUNTY, FLORIDA ANA L. MIRANDA, CASE NO: 35-2021-CA-001576-AXXX-XX Plaintiff, vs. TRAVIS N. WARD AND GEICO GENERAL INSURANCE COMPANY, Defendant. / OBJECTION TO PRODUCTION FROM NON-PARTIES Plaintiff, ANA L. MIRANDA, by and through the undersigned attorneys, pursuant to Rule 1.351(b) of the Florida Rules of Civil Procedure, hereby files this Objection to Production from Non-Party providers listed on Defendant’s Notice of Production from Non-Party dated December 8, 2021, for the following parties: 1 CarePlus Health Plans, INC. Corporation Service Company 1201 Hays Street. Tallahassee, FL 32301 Davenport Medical Center 2500 Berry Blvd Davenport, FL 33897 Plaintiff requests that no subpoena be served pursuant to Rule 1.351. As grounds for such objection, the undersigned has had difficult experiences with other attorneys relating to questionable practices involving Notice of Production of Non-Parties and based upon that experience, and other similar ones, the undersigned now is caused to object to all Notices of Production in all cases. However, the Defendant may promptly obtain the same information without delay by utilizing Rule 1.310, by way of a records pick-up, deposition or, including FILED: LAKE COUNTY, GARY J. COONEY, CLERK, 12/14/2021 10:55:26 AM Plaintiffs counsel as a party to obtain the same records being produced to Defendant on the Subpoena Duces Tecum. Defense counsel is requested not to issue any subpoenas. CERTIFICATE OF SERVICE THEREBY CERTIFY that on December 3, 2021, I electronically filed the foregoing with the Clerk of the Courts by using the Florida Courts eFiling Portal which will send notification of electronic filing to the following: Joshua M. Parks, Esquire at the Law Office of Terryl Blackmon Walker, 901 N. Lake Destiny Road, Suite 105 Maitland, FL 32751; [Joshua_M_Parks@Progressive.com], and Michael J. Stewart, Esquire at the Law Office of Sarah E. Blazak, 111 North Orange Avenue, Suite 1600, Orlando, Florida 32801 ;[mistewart@geico.com]. Eloisa Pino, Esquire FBN: 1025065 Morgan & Morgan, P.A. 20 N. Orange Avenue Suite 1600 Orlando, FL 32801 Telephone: (689) 219-2080 Facsimile: (689) 219-2180 Primary email: epino@forthepeople.com Secondary email: bcarpanzano@forthepeople.com Attorneys for Plaintiff