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`
`#5296391.1
`#5311389.1
` IN THE CIRCUIT COURT, FOURTH
`JUDICIAL CIRCUIT, IN AND FOR DUVAL
`COUNTY, FLORIDA
`CASE NO.: 16-2025-CA-002557-AXXX-MA
`DIVISION: CV-D
`LYNNE PILKERTON,
`
`Plaintiff,
`vs.
`MELANIE KAY BRADLEY and
`USAA CASUALTY INSURANCE
`COMPANY,
`
`Defendants.
`____________________________________
`DEFENDANT’S CERTIFICATE OF NON-OBJECTION RE:
`TO:
`Records Custodian
`Baptist Medical Center-Nassau
`462600 State Road 200
`Yulee FL 32097
`
`Records Custodian
`Baptist & Wolfson Nassau Crossing
`462600 SR 200
`Yulee FL 32097
`
`Records Custodian
`Coastal Injury Clinic - Riverside
`463386 State Road 200
`Yulee FL 32097-3240
`
`Records Custodian
`Coastal Spine & Pain Center
`404 NW Hall of Fame Drive
`Lake City FL 32055-4833
`
`Records Custodian
`Emergency Resources Group
`Post Office Box 748943
`Atlanta GA 30374
`
`Records Custodian
`Fernandina Chiropractic Center
`463392 E SR 200
`Yulee FL 32097
`
`Records Custodian
`Florida Seizure DOC LLC
`495 Grand Boulevard Suite 206
`Miramar Beach FL 32550
`
`Records Custodian
`Precision Imaging Center
`7860 Gate Parkway, Unit 123
`Jacksonville, FL 32256
`
`Records Custodian
`Mori Bean & Brooks
`c/o Corporation Service Company
`1201 Hays Street
`Tallahassee, FL32301
`Records Custodian
`Universal Neurological Care
`8823 San Jose Blvd., Suite 209
`Jacksonville, FL 32217
`
`
`
`
`
`Filing # 225980022 E-Filed 06/25/2025 10:42:06 AM
`ACCEPTED: DUVAL COUNTY, JODY PHILLIPS, CLERK, 06/25/2025 10:42:14 AM
`
`
`
`
`
`
`
`
`
`#5296391.1
`#5311389.1
`Records Custodian
`GEICO
`3535 W Pipkin Road
`Lakeland FL 33811
`
`Records Custodian
`Medicare
`Post Office Box 138897
`Oklahoma City OK 73113
`
`Records Custodian
`The Rawlings Company
`One Eden Parkway
`LaGrange KY 40031-8100
`
`Records Custodian
`Universal Property & Casualty Insurance Co
`1110 W Commercial Boulevard
`Ft. Lauderdale FL 33309
`
`Records Custodian
`USAA
`9800 Fredericksburg Road
`San Antonio TX 78288
`
`Records Custodian
`CVS Pharmacy
`One CVS Drive
`Woonsocket RI 02895
`
`Records Custodian
`Publix Stores - Privacy Officer
`3300 Publix Corp Parkway
`Lakeland FL 33811
`
`Records Custodian
`Wal-Mart Pharmacy
`Legal Dept, Mail Stop 0215
`702 SW 8th Street
`Bentonville AR 72716-0215
`
`Records Custodian
`Walgreens Pharmacy
`1901 E Voorhees
`Danville IL 61834
`
`Records Custodian
`Winn-Dixie Pharmacy
`8928 Prominence Parkway, Bldg.+ 200
`Jacksonville FL 32256
`
`Pursuant to Florida Rules of Civil Procedure 1.351, a Notice of Production from Non-Party
`was served upon counsel for the Plaintiff under Certificate of Service dated June 10, 2025. Plaintiff
`has been notified that these records have been requested and is not objecting to the production
`of the records delineated in the attached non-party subpoena that is directed to you. This
`information is sought in connection with a judicial proceeding that has been i nitiated by the
`Plaintiff. In compliance with 45 CFR § 164.512(e)(1), the Defendant has made a good faith
`attempt to provide written notice to the Plaintiff that included sufficient i nformation regarding the
`records being requested and the litigation to which the request pertains, and allowed the Plaintiff
`time to raise an objection. The Plaintiff has not raised an objection an d the time within which to
`do so has expired.
`Pursuant to Florida Rules of Civil Procedure 1.351 and 45 CFR § 164.512(e)(1), the
`Defendant respectfully requests that you produce the documents requested in the attached
`subpoena, at the time and place specified therein.
`
`
`
`
`
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`
`
`
`#5296391.1
`#5311389.1
`CERTIFICATE OF SERVICE
`I HEREBY CERTIFY that on this 23 rd day of June, 2025, I electronically filed the
`foregoing with the Florida Courts E-Filing Portal, which will serve it on the following counsel of
`record via electronic mail:
`Ashley B. Winstead, Esquire
`MORGAN & MORGAN, P.A.
`501 Riverside Avenue, Suite 1200
`Jacksonville, Florida 32202
`Email: awinstead@forthepeople.com
`Email: jillj@forthepeople.com
`Email: hweltz@forthepeople.com
`Attorney for Plaintiff
`
`
`_______________________________
`Steven L. Worley
`Florida Bar No. 0159719
`James M. Oliver
`Florida Bar No. 124458
`CARR ALLISON
`The Truist Building
`200 W. Forsyth Street, Suite 600
`Jacksonville, Florida 32202
`Telephone: (904) 328-6456
`Facsimile: (904) 328-6473
`Email: sworley@carrallison.com
`Email: joliver@carrallison.com
`Secondary Email: jdavis@carrallison.com
`Secondary Email: schurch@carrallison.com
`Attorneys for Defendant, Melanie Kay
`Bradley
`
`
`
`
`
`
`
`
`
`

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