`
`IN THE CIRCUIT COURT OF THE
`11TH JUDICIAL CIRCUIT, IN AND FOR
`MIAMI-DADE COUNTY, FLORIDA
`
`CASE NO: 2020-027081-CA-01
`
`KAVITA CLARK, TERRY PERSAD,
`MAUREENA PERSAD, and NAVITA
`PERSAD,
`
` Plaintiffs,
`
`vs.
`
`AMCK TRANSPORT, INC. and
`LEMAY VALDES MONTES
`
` Defendants.
`________________________________/
`
`OBJECTION TO NOTICE OF PRODUCTION FROM NON-PARTIES
`
`Plaintiff, KAVITA CLARK, by and through her undersigned counsel, files this Objection to
`
`Defendant’s, notice of intent to serve subpoena under rule 1.351 for production of documents
`
`and things without deposition dated June 20, 2021 directed to the following non-parties:
`
`1. Stephen T. Divito, DC - Objection, relevance, harassing, invasion of privacy as to any
`financial/billing information.
`2. Rochester General Hospital - Objection, relevance, harassing, invasion of privacy as to
`any financial/billing information.
`3. Human Resources Rochester General Hospital - Objection, harassing, invasion of privacy
`as to any financial information and reason for termination of employment, as Plaintiff is
`not making a wage claim.
`4. Empire Blue Cross Blue Shield - Objection, relevance, harassing, invasion of privacy as
`to any financial/billing information.
`5. United Healthcare - Objection, relevance, harassing, invasion of privacy as to any
`financial/billing information.
`6. Monroe Community College – Objection overbroad, relevance, harassing, invasion of
`privacy.
`7. The College at Brockport State University of New York – Objection overbroad,
`relevance, harassing, invasion of privacy.
`
`CERTIFICATE OF SERVICE
`
`1
`
`
`
`I HEREBY CERTIFY that a true and correct copy of the foregoing has been served on June 20,
`2021 via electronic filing pursuant to Florida Rule of Judicial Administration 2.516 to Anthony
`Gonzales of Carman, Beauchamp, Sang, Gonzales & Philpott, PA., 2225 NW Boca Raton Blvd.
`Boca
`Raton,
`FL
`33431
`at
`agonzales@carmanbeauchamp.com
`and
`rhian@carmanbeauchamp.com.
`
`WILLIAMS HILAL WIGAND GRANDE
`Attorneys for Plaintiff(s)
`2924 Davie Road, Suite 201
`Ft. Lauderdale, FL 33314
`Tel:
`(954) 639-4561
`Fax:
`(954) 639-4559
`e-mail: chris@thewigandlawfirm.com
`
`
`BY:____________________________
`Christopher Wigand
`Fla. Bar No. 175439
`
`
`
`2
`
`
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