UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CIVIL DIVISION

DEVIN FILIPPELLI as 

Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, CASE NO.: 9:22-cv-81731 

on behalf of the Estate and her Survivors, 

Plaintiff,

v. 

GROW, LLC (b/d/a KD INCORPORATED 

and THE KRATOM DISTRO); and SEAN 

MICHAEL HARDER, individually. 

Defendants. /

NOTICE OF FILING PROPOSED ORDER ON PLAINTIFF’S MOTION TO COMPEL 

DEFENDANTS TO PRODUCE INITIAL DISCLOSURES

Plaintiff submits the Proposed Order Granting Plaintiff’s Motion to Compel Defendants 

to Produce Initial Disclosures. 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 20th day of January, 2023, a true electronic copy of the 

foregoing was electronically filed with the Clerk of the Court using the CM/ECF system, and has 

been submitted to Defendants’ counsel, Bowman and Brooke LLP, Justin Niznik Esq., 1064 

Greenwood Blvd. #212, Lake Mary, FL 32746, at justin.niznik@bowmanandbrooke.com; 

orfa.diaz@bowmanandbrooke.com; and kara.thomas@bowmanandbrooke.com.

________________________________ 

Michael J. Cowgill, Esq. 

Florida Bar No. 1010945

Tamara J. Williams, Esq. 

Florida Bar No. 127625 

Case 9:22-cv-81731-DMM Document 24 Entered on FLSD Docket 01/20/2023 Page 1 of 4
mctlaw 

1605 Main Street, Suite 710 

Sarasota, FL 34236 

Telephone: 888.952.5242 

Facsimile: 941.952.5042 

Primary: mcowgill@mctlaw.com

Primary: twilliams@mctlaw.com

Secondary: hdiener@mctlaw.com

Secondary: mpowell@mctlaw.com

Attorneys for Plaintiff

Case 9:22-cv-81731-DMM Document 24 Entered on FLSD Docket 01/20/2023 Page 2 of 4
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CIVIL DIVISION

DEVIN FILIPPELLI as 

Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, CASE NO.: 9:22-cv-81731 

on behalf of the Estate and her Survivors, 

Plaintiff,

v. 

GROW, LLC (b/d/a KD INCORPORATED 

and THE KRATOM DISTRO); and SEAN 

MICHAEL HARDER, individually. 

Defendants.

_______________________________________/

[PROPOSED] ORDER GRANTING PLAINTIFF’S MOTION TO COMPEL 

DEFENDANTS TO PRODUCE INITIAL DISCLOSURES

This matter is before the Court on the Motion to Compel Defendants to Produce Initial 

Disclosures filed herein by Plaintiff, DEVIN FILIPPELLI as Personal Representative of the 

ESTATE OF KRYSTAL TALAVERA, on behalf of the Estate and her Survivors.

Having considered all papers filed in connection with Plaintiff’s motion, the Court finds 

that it is appropriate to compel Defendants to produce initial disclosures pursuant to Rule 26. 

Therefore, it is 

ORDERED AND ADJUDGED as follows:

1. Plaintiff’s motion to compel is hereby GRANTED. 

Case 9:22-cv-81731-DMM Document 24 Entered on FLSD Docket 01/20/2023 Page 3 of 4
2. Defendants, GROW LLC (d/b/a KD Incorporated and the Kratom Distro) and Sean 

Michael Harder, must produce initial disclosures pursuant to Rule 26(a)(1)(A)(i-iv) on or before 

January 25, 2023.

DONE and ORDERED in Chambers this ______ day of ___________________ 2023. 

 ___________________________________

 The Honorable Donald M. Middlebrooks 

 United States District Court Judge 

 Southern District of Florida 

cc: All counsel of record

Case 9:22-cv-81731-DMM Document 24 Entered on FLSD Docket 01/20/2023 Page 4 of 4