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Filing # 141316316 E-Filed 01/04/2022 02:22:24 PM
2152953
IN THE CIRCUIT COURT OF THE 15TH JUDICIAL
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502021CA010079XXXXMB DIV. AA
VIOLECIA JACQUET BRUNO;
Plaintiff,
v.
SUMMERLAND POOLS, INC. and ELI J.
ETZLER,
Defendants.
/
DEFENDANTS’ REQUEST TO PRODUCE TO PLAINTIFF
Defendants, SUMMERLAND POOLS, INC. and ELI J. ETZLER, request that the
Plaintiff, VIOLECIA JACQUET BRUNO, pursuant to Florida Rules of Civil Procedure,
Rule 1.350, produce the following within thirty (30) days from the date of this Request:
1. True and correct copies of Plaintiffs Federal Income Tax Returns for the
vaare 9N17 9N1Q2 9N1Q 9NIN and 2021, whan filod if a claim far Inst wanes ie haina
yw ae av.
ars 2017, 2078, 2019, 20. When Med wn tor ages iS Seng
made.
2. Photographs and/or films in the possession, custody or control of the
Plaintiff, Plaintiffs agents, servants or attorneys, showing the scene of the accident or
incident and the damage or injury to the vehicles, and/or persons involved.
3. Copies of all medical bills, nursing bills, drug bills, and all other bills
supporting Plaintiffs claim for damages herein, together with all existing medical, dental
CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDIZ A4INAINNAD ND.99.94 DNA
Pm. PAL DLA VUUINE TT, PL, JUOL I mDnueey, ULUIAN, UU cue. Ue.26.2 FMCASE NO. 502021CA010079XXXXMB DIV. AA
and hospital records and reports of Plaintiffs condition of ill health, if any, claimed to be
related to the incident which is the subject matter of this cause.
4. All of the tangible things within the possession, custody, or control of the
Plaintiff herein upon which the claims and defenses herein are based, and specifically,
but not limited to, writings, drawings, graphs, charts, photographs, movies, slides, film,
video tape, phonograph records and other recording devices, instruments, equipment,
real and personal property, objects, goods and/or vehicles or operations which are the
subjects of the claims and defenses herein, so that same may be inspected, copied,
tested, measured, surveyed, and photographed, pursuant to Rule 1.350, Florida Rules of
Civil Procedure.
5. All ordinances, regulations, rules, statutes, customs and practices, and
publications upon which your claim and counter-defenses herein are made.
6. Traffic or other Court transcripts involving the subject matter of the instant
litigation.
7. All documents and items specified in your Answers to Interrogatories as
coming within Ruie 7.350(c), Fiorida Rules of Civil Procedure, exercising tne option to
produce records in lieu of summary based on said records and reports.
8. All statements obtained by you, or your attorneys, of the Defendant, the
agents, servants and employees of Defendant, either recorded or written, at the time of
or subsequent to the subject accident or incident.
9. Copies of any agreements entered into by you or on your behalf with any
other Defendant, person, firm, or corporation whom you contend may have some liability
avinnetira far tha eithiart annidant ar insidant
SApCsure 1Cr wie Sunyeur GCCIUein Gr moiUcin,CASE NO. 502021CA010079XXXXMB DIV. AA
10. A copy of any Medicare card that has been issued to you; any
communication(s) from Medicare that you are entitled to or will become eligible for
Medicare benefits; any and all claim(s) and/or application(s) along with all other
documentation including medical records submitted in any written or electronic form to
the Social Security Administration for disability benefits; any and all decision(s) in any
form from the Social Security Administration regarding any claim for disability benefits;
any and all appeal(s) and/or decision(s) from the Social Security Administration regarding
any claim(s) for disability benefits; any and all decision(s) from an Administrative Law
Judge regarding any claim(s) for disability benefits; and any and all explanation of benefits
notice(s) from the Center for Medicare and Medicaid Services.
CERTIFICATE OF SERVICE
| HEREBY CERTIFY that a copy of the foregoing has been served on all Counsel
of Record via the Florida E-Filing Portal 4th day of January, 2022.
CONROY SIMBERG
Attorney for Defendant, Summerland Pools, Inc.
1801 Centrepark Drive East, Suite 200
West Palm Beach, FL 33401
Talanhana. /£24\ 207 ONDo
IGIEpHnone. (VOI) OYs-OV0O
Facsimile: (561) 697-8664
Primary Email: eservicewpb@conroysimberg.com
Secondary Email: jblaker@conroysimberg.com
By: isi felfrey x8. Biakon
Jeffrey A. Blaker, Esquire
Florida Bar No. 443913
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Filing # 141316316 E-Filed 01/04/2022 02:22:24 PM 2152953 IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502021CA010079XXXXMB DIV. AA VIOLECIA JACQUET BRUNO; Plaintiff, v. SUMMERLAND POOLS, INC. and ELI J. ETZLER, Defendants. / DEFENDANTS’ REQUEST TO PRODUCE TO PLAINTIFF Defendants, SUMMERLAND POOLS, INC. and ELI J. ETZLER, request that the Plaintiff, VIOLECIA JACQUET BRUNO, pursuant to Florida Rules of Civil Procedure, Rule 1.350, produce the following within thirty (30) days from the date of this Request: 1. True and correct copies of Plaintiffs Federal Income Tax Returns for the vaare 9N17 9N1Q2 9N1Q 9NIN and 2021, whan filod if a claim far Inst wanes ie haina yw ae av. ars 2017, 2078, 2019, 20. When Med wn tor ages iS Seng made. 2. Photographs and/or films in the possession, custody or control of the Plaintiff, Plaintiffs agents, servants or attorneys, showing the scene of the accident or incident and the damage or injury to the vehicles, and/or persons involved. 3. Copies of all medical bills, nursing bills, drug bills, and all other bills supporting Plaintiffs claim for damages herein, together with all existing medical, dental CHEN. DAIAARCACUAAIINTY Cl INGEDU ARDIIV7ZN FLEDIZ A4INAINNAD ND.99.94 DNA Pm. PAL DLA VUUINE TT, PL, JUOL I mDnueey, ULUIAN, UU cue. Ue.26.2 FMCASE NO. 502021CA010079XXXXMB DIV. AA and hospital records and reports of Plaintiffs condition of ill health, if any, claimed to be related to the incident which is the subject matter of this cause. 4. All of the tangible things within the possession, custody, or control of the Plaintiff herein upon which the claims and defenses herein are based, and specifically, but not limited to, writings, drawings, graphs, charts, photographs, movies, slides, film, video tape, phonograph records and other recording devices, instruments, equipment, real and personal property, objects, goods and/or vehicles or operations which are the subjects of the claims and defenses herein, so that same may be inspected, copied, tested, measured, surveyed, and photographed, pursuant to Rule 1.350, Florida Rules of Civil Procedure. 5. All ordinances, regulations, rules, statutes, customs and practices, and publications upon which your claim and counter-defenses herein are made. 6. Traffic or other Court transcripts involving the subject matter of the instant litigation. 7. All documents and items specified in your Answers to Interrogatories as coming within Ruie 7.350(c), Fiorida Rules of Civil Procedure, exercising tne option to produce records in lieu of summary based on said records and reports. 8. All statements obtained by you, or your attorneys, of the Defendant, the agents, servants and employees of Defendant, either recorded or written, at the time of or subsequent to the subject accident or incident. 9. Copies of any agreements entered into by you or on your behalf with any other Defendant, person, firm, or corporation whom you contend may have some liability avinnetira far tha eithiart annidant ar insidant SApCsure 1Cr wie Sunyeur GCCIUein Gr moiUcin,CASE NO. 502021CA010079XXXXMB DIV. AA 10. A copy of any Medicare card that has been issued to you; any communication(s) from Medicare that you are entitled to or will become eligible for Medicare benefits; any and all claim(s) and/or application(s) along with all other documentation including medical records submitted in any written or electronic form to the Social Security Administration for disability benefits; any and all decision(s) in any form from the Social Security Administration regarding any claim for disability benefits; any and all appeal(s) and/or decision(s) from the Social Security Administration regarding any claim(s) for disability benefits; any and all decision(s) from an Administrative Law Judge regarding any claim(s) for disability benefits; and any and all explanation of benefits notice(s) from the Center for Medicare and Medicaid Services. CERTIFICATE OF SERVICE | HEREBY CERTIFY that a copy of the foregoing has been served on all Counsel of Record via the Florida E-Filing Portal 4th day of January, 2022. CONROY SIMBERG Attorney for Defendant, Summerland Pools, Inc. 1801 Centrepark Drive East, Suite 200 West Palm Beach, FL 33401 Talanhana. /£24\ 207 ONDo IGIEpHnone. (VOI) OYs-OV0O Facsimile: (561) 697-8664 Primary Email: eservicewpb@conroysimberg.com Secondary Email: jblaker@conroysimberg.com By: isi felfrey x8. Biakon Jeffrey A. Blaker, Esquire Florida Bar No. 443913