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wes CASE NUMBER: 502020CA014445XXXXMB Div: AF ****
Filing # 118649191 E-Filed 12/22/2020 05:32:17 PM
IN THE CIRCUIT COURT OF THE 15TH
JUDICIAL CIRCUIT OF FLORIDA, IN AND
FOR PALM BEACH COUNTY
JANE DOE,
GENERAL JURISDICTION DIVISION
Plaintiff,
v. Case No:
DBUUA KALUIN REULUVINAL NUSrILAL,
INC. d/b/a BOCA RATON REGIONAL
HOSPITAL, and
DEVON BRIGANTI,
Defendants.
/
PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFE!
BRIGANTI, ED TECH
iT. DEVON
The Plaintiff, JANE DOE, by and through the undersigned, propounds this Request for
Production to Defendant, DEVON BRIGANTI, ED TECH hereinafter. The Defendant is to
respond to said Request for Production on or before thirty (30) days of receipt of service.
1. Acomplete copy of any insurance policies and declaration pages for any liability insurance
policy that may cover the damages complained of in this lawsuit.
RESPONSE:
2. A complete copy of DEVON BRIGANTI, ED TECH employment file for any prior
employment he had.
RESPONSE:
3. Complete copies of any and all written or audio complaints made against DEVON
BRIGANTI, ED TECH arising from your employment at any medical facility, including
but not limited to, employment as an ED Tech.
RESPONSE:
CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAY FLED 49:INDINNIN NE-29.47 DAA
PILL. PALE BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, 12ieereucu vl.ue. 6 ive10.
First Request for Production to Defendant - Briganti
Page 2 of 4
A copy of DEVON BRIGANTI, ED TECH’S CV and/or resume that was provided to
BOCA RATON REGIONAL HOSPITAL prior to being hired.
RESPONSE:
Any and all records in your possession related to, regarding, used during, and/or provided
to you during any and all Department of Health investigation in DEVON BRIGANTI, ED
TECH.
RESPONSE:
Any and all writings, emails, text messages, voicemails, reports, investigative materials, or
other documents Telating to or regarding the 2020 alleged sexual battery committed by
DEVON BRIGANTI, ED TECH. if any of these documenis are considered aitorney-citent
privileged communications or documents, please provide a privilege log.
RESPONSE:
Any and all Photographs, audio, and/or videos relating to or regarding the 2020 sexual
nannelt vnenent DEVAN DPIC ANTI ON TOOT
assaunt committed by VEVUIN DRIVAN LI, bY 1Un.
RESPONSE:
Any and all written communications between BOCA RATON REGIONAL HOSPITAL,
INC. d/b/a BOCA RATON REGIONAL HOSPITAL and DEVON BRIGANTI, ED
TRC
RESPONSE:
A copy of the official job duties and/or functions of DEVON BRIGANTI, ED TECH for
2020.
RESPONSE:
Copies of any and all reviews of DEVON BRIGANTI, ED TECH from BOCA RATON
REGIONAL HOSPITAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL.
RESPONSE:First Request for Production to Defendant - Briganti
Page 3 of 4
11. Copies of any and all reviews of DEVON BRIGANTI, ED TECH from any healthcare
facilities (hospital, nursing home, medical facility, etc.) where you have worked in the past
five (5) years.
RESPONSE:
12. Any and all documents, writings, letters, and/or correspondences sent to the Fl
Department of Health which the alleged sexual battery perpetrated by DEVON
BRIGANTI, ED TECH.
RESPONSE:
13. Please provide any and all documents, pleadings, court filings, or other writing related to,
concerning, and/or used during ine case captioned: Siaie of Moriaa vs. Devon F’. Briganti
Case No. 50-2020-CF-000622-AXXX-MB
RESPONSE:
14. Any and all documents, letters, memorandums, or other materials detailing your
Cre anne Carine a.
iS 10i Saie, wOni ai
elane Af aed eat ver Bn nant
place O1 CiipiOyinicin Witnin wie pase
fifteen (15) years.
RESPONSE:
15. Any and all non-privileged documents, letters, memorandums, text messages, emails, or
ather materiale in var nacceccian dicenceina addraccina and/ar ralated ta anv and all nact
Ouner Mareriaas ih Yur PUSSession GiSCussing, GGGressing ana, Cr Tada tC any ana du past
allegations of sexual harassment, sexual assault, and/or sexually inappropriate conducted
that has been made against you during any employment you have held for the past five (5)
years.
RESPONSE:
CERTIFICATE OF SERVICE
WE HEREBY CERTIFY that a true and correct copy of the foregoing shall be served along
with the Summons and Complaint in this action.
Si payin J. preva, BSG.
David J. Brevda, Esq.
Florida Bar No.: 1008373
3First Request for Production to Defendant - Briganti
Page 4 of 4
Senior Justice Law Firm
7700 Congress Ave., Suite 3216
Boca Raton, Florida 33487
Phone: (561) 717-0813
Fax: (561) 708-6781
Email: eservice@SeniorJustice.com
Attorney for Plaintiff
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wes CASE NUMBER: 502020CA014445XXXXMB Div: AF **** Filing # 118649191 E-Filed 12/22/2020 05:32:17 PM IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR PALM BEACH COUNTY JANE DOE, GENERAL JURISDICTION DIVISION Plaintiff, v. Case No: DBUUA KALUIN REULUVINAL NUSrILAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL, and DEVON BRIGANTI, Defendants. / PLAINTIFF'S FIRST REQUEST FOR PRODUCTION TO DEFE! BRIGANTI, ED TECH iT. DEVON The Plaintiff, JANE DOE, by and through the undersigned, propounds this Request for Production to Defendant, DEVON BRIGANTI, ED TECH hereinafter. The Defendant is to respond to said Request for Production on or before thirty (30) days of receipt of service. 1. Acomplete copy of any insurance policies and declaration pages for any liability insurance policy that may cover the damages complained of in this lawsuit. RESPONSE: 2. A complete copy of DEVON BRIGANTI, ED TECH employment file for any prior employment he had. RESPONSE: 3. Complete copies of any and all written or audio complaints made against DEVON BRIGANTI, ED TECH arising from your employment at any medical facility, including but not limited to, employment as an ED Tech. RESPONSE: CHEN. DAIAARCACUAAIINTY Cl CUADAND ANAY FLED 49:INDINNIN NE-29.47 DAA PILL. PALE BLAU VUUINE TT, EL, OHI. DUUN, ULLIAN, 12ieereucu vl.ue. 6 ive10. First Request for Production to Defendant - Briganti Page 2 of 4 A copy of DEVON BRIGANTI, ED TECH’S CV and/or resume that was provided to BOCA RATON REGIONAL HOSPITAL prior to being hired. RESPONSE: Any and all records in your possession related to, regarding, used during, and/or provided to you during any and all Department of Health investigation in DEVON BRIGANTI, ED TECH. RESPONSE: Any and all writings, emails, text messages, voicemails, reports, investigative materials, or other documents Telating to or regarding the 2020 alleged sexual battery committed by DEVON BRIGANTI, ED TECH. if any of these documenis are considered aitorney-citent privileged communications or documents, please provide a privilege log. RESPONSE: Any and all Photographs, audio, and/or videos relating to or regarding the 2020 sexual nannelt vnenent DEVAN DPIC ANTI ON TOOT assaunt committed by VEVUIN DRIVAN LI, bY 1Un. RESPONSE: Any and all written communications between BOCA RATON REGIONAL HOSPITAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL and DEVON BRIGANTI, ED TRC RESPONSE: A copy of the official job duties and/or functions of DEVON BRIGANTI, ED TECH for 2020. RESPONSE: Copies of any and all reviews of DEVON BRIGANTI, ED TECH from BOCA RATON REGIONAL HOSPITAL, INC. d/b/a BOCA RATON REGIONAL HOSPITAL. RESPONSE:First Request for Production to Defendant - Briganti Page 3 of 4 11. Copies of any and all reviews of DEVON BRIGANTI, ED TECH from any healthcare facilities (hospital, nursing home, medical facility, etc.) where you have worked in the past five (5) years. RESPONSE: 12. Any and all documents, writings, letters, and/or correspondences sent to the Fl Department of Health which the alleged sexual battery perpetrated by DEVON BRIGANTI, ED TECH. RESPONSE: 13. Please provide any and all documents, pleadings, court filings, or other writing related to, concerning, and/or used during ine case captioned: Siaie of Moriaa vs. Devon F’. Briganti Case No. 50-2020-CF-000622-AXXX-MB RESPONSE: 14. Any and all documents, letters, memorandums, or other materials detailing your Cre anne Carine a. iS 10i Saie, wOni ai elane Af aed eat ver Bn nant place O1 CiipiOyinicin Witnin wie pase fifteen (15) years. RESPONSE: 15. Any and all non-privileged documents, letters, memorandums, text messages, emails, or ather materiale in var nacceccian dicenceina addraccina and/ar ralated ta anv and all nact Ouner Mareriaas ih Yur PUSSession GiSCussing, GGGressing ana, Cr Tada tC any ana du past allegations of sexual harassment, sexual assault, and/or sexually inappropriate conducted that has been made against you during any employment you have held for the past five (5) years. RESPONSE: CERTIFICATE OF SERVICE WE HEREBY CERTIFY that a true and correct copy of the foregoing shall be served along with the Summons and Complaint in this action. Si payin J. preva, BSG. David J. Brevda, Esq. Florida Bar No.: 1008373 3First Request for Production to Defendant - Briganti Page 4 of 4 Senior Justice Law Firm 7700 Congress Ave., Suite 3216 Boca Raton, Florida 33487 Phone: (561) 717-0813 Fax: (561) 708-6781 Email: eservice@SeniorJustice.com Attorney for Plaintiff